In Butler v. St. Stanislaus Kostka Catholic Academy, (ED NY, June 27, 2022), a New York federal district court dismissed a sexual orientation discrimination lawsuit brought by Cody Butler, a teacher of English Language Arts and Social Studies who was fired from his Catholic school teaching position shortly after he was hired. After his first teacher orientation session, Butler e-mailed the principal saying that the orientation made him uncomfortable because he is homosexual and plans in the future to marry his boyfriend. Within days, Butler was given a letter of termination. The court dismissed the suit on both ministerial exception and church autonomy grounds. As to the ministerial exception, the court said in part:
[E]xtensive evidence leaves no doubt that Butler’s job did, and would have continued to, include important ministerial duties....
Butler argued that the school's claim he was fired because his intended same-sex marriage which violated church doctrine was a pretext for firing him because of his sexual orientation. The court said in part:
[T]he only way for the jury to find pretext would be to question the Church’s explanation of religious doctrine, or to question how much that particular religious doctrine really mattered to the Church. To do so, however, would violate the church-autonomy principle....
The bottom line is that courts have long recognized the church-autonomy doctrine, and no binding authority has ever said that the ministerial exception eclipses this doctrine in employment-discrimination cases.... I am constrained to conclude that no such limitation exists. Under controlling case law, the church autonomy doctrine applies in the employment-discrimination context, as it does elsewhere. And this principle forecloses judicial inquiry into the plausibility of St. Stans’ asserted religious justifications in this case....
[Thanks to Mark Chopko for the lead.]
