Factual Questions Remain On Ecclesiastical Abstention and Ministerial Exception

In Kelley v. Decatur Baptist Church, (ND AL, May 1, 2018), an Alabama federal magistrate judge refused to dismiss a Title VII pregnancy discrimination lawsuit brought by a maintenance and child care employee of a church.  The court held that factual questions exist as to whether the ecclesiastical abstention doctrine applies. Plaintiff claims she was fired because she was pregnant.  Defendant contends she was fired because she engaged in sexual conduct outside of marriage in violation of Biblical standards.  The court also held that factual questions exist as to whether the ministerial exception doctrine applies.  Plaintiff challenged defendant's characterization of her as a minister charged with equipping, training, and evangelizing the next  generation according to biblical standards and morals.