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THE MINISTERIAL EXCEPTION DOES NOT PRECLUDE THIS HOSTILE-WORK-ENVIRONMENT ACTION BY EMPLOYEES OF A PRIVATE CATHOLIC HIGH SCHOOL; THE MINISTERIAL EXCEPTION PRECLUDES ACTIONS AGAINST RELIGIOUS INSTITUTIONS WHICH INTERFERE WITH RELIGIOUS DOCTRINE; THE ALLEGATIONS OF HARASSMENT BY SCHOOL OFFICIALS DO NOT INVOLVE RELIGIOUS DOCTRINE (FIRST DEPT). ​

The First Department, reversing Supreme Court, determined the-hostile work-environment causes of action by employees of a private Catholic high school should not have been dismissed pursuant to the “ministerial exception” which, in certain circumstances, will preclude employment discrimination actions against a religious institution:

Plaintiffs … were all employed by … a private Catholic school . The case stems from plaintiffs’ allegations that the school’s Principal … regularly subjected them to vulgar, sexist, ageist, racist and homophobic remarks and epithets. Plaintiffs further allege that … the school’s Vice Principal … and … the school’s Dean of Men, regularly repeated [the Principal’s] vile language and assisted in his efforts to discriminate against staff. In addition, plaintiffs allege that … the head of defendant Archdiocese of New York … and the defendant Archdiocese knew about [the Principal’s] conduct but did nothing to stop it.

Plaintiffs’ claims for hostile work environment were improperly dismissed under the ministerial exception, which precludes some employment claims against religious institutions on First Amendment grounds … . Although the ministerial exception was created to protect churches from state interference in their decisions to employ and supervise ministerial employees, it was not intended as a shield from all types of workplace conduct … . * * *

Here, plaintiffs are correct that there is no religious justification for [the Principal’s] appalling conduct, and analyzing their hostile work environment claims would not require the Court to improperly interfere with religious doctrine or defendants’ personnel decisions. Boliak v Reilly, 2025 NY Slip Op 07088, First Dept 12-18-25

Practice Point: Some employment discrimination actions against religious institutions are barred by the ministerial exception. Here the allegations plaintiffs, employees of a private Catholic School, were harassed by school officials did not require a court’s interference with religious doctrine and therefore were not precluded by the ministerial exception.​

 

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