In Davenport v. Episcopal Health Services, Inc., (ED NY, Feb. 5, 2026), a New York federal district court held that the ministerial exception doctrine bars Title IX and Fair Labor Standards Act claims by a student chaplain in an Episcopal hospital. The court said in part:
Plaintiff Archbishop Russell Davenport served as a chaplain at St. John’s Episcopal Hospital South Shore [EHS]... as part of the hospital’s clinical pastoral education program. But he claims the hospital never paid him for spiritual and clinical counseling that he performed for patients after his shift ended. He separately claims that the hospital improperly rejected his sexual harassment complaint against a fellow chaplain but suspended him when another employee filed a complaint against him....
Plaintiff contends that EHS is not a religious group because the complaint “makes no allegations about the religious origins or continuing religious purpose of the hospital.” ...
Like the Department of Pastoral Care, the CPE program offers “pastoral services to patients and community members.” ... Its chaplains perform religious rituals and rites, worship with patients, and offer spiritual counsel.... The CPE’s work therefore also vests in Defendants a critical aspect of its religious entity—even if its services are not strictly Episcopalian. That indisputably religious service renders St. John’s and EHS religious groups....
Plaintiff insists that the ministerial exception does not apply to students. But he adduces no authority why the exception excludes those who administer religious services simply because they obtain “professional training and education for ministry” part-time....
The ministerial exception applies to Plaintiff’s wage-and-hour claims. Just “as the initial function of selecting a minister is a matter of church administration and government, so are the functions which accompany such a selection,” including “determination of a minister’s salary.”...