Main Reason behind the Case
The main reason behind the case Our Lady of Guadalupe School v. Morrissey-Berru was to hold a determination on whether the Religious Clause dictates employment discrimination claims against a religious organization. The Hosanna-Tabor exception explained that young people living in their faith, involved in teaching and training other people, are the responsibility of the institution they work for but should not be abused by any means.
Facts
Agnes Morrissey-Berru and Kristen Biel were teachers at Our Lady of Guadalupe School and St. James School, respectively. Both were employed under an almost similar agreement, which set out the school’s mission related to developing and promoting the Catholic School faith community (Harvard Law Review, 2020). Each teacher taught religion and worshiped together with their respective students (Harvard Law Review, 2020). After their employment was terminated, both teachers sued the school’s administration.
Morrissey-Berru argued that OLG’s reason for demoting her was to replace her with a younger teacher, which violated the Age Discrimination in Employment Act of 1967. Consequently, OLG activated the ministerial exception that was set in Hosanna-Tabor Evangelical Lutheran Church and School v. EEOC, 565 U. S. 171, 132 S. Ct. 694, 181 L. Ed. 2d 650 (Harvard Law Review, 2020). This was later moved for the purpose of summary judgment. Nonetheless, the Ninth Circuit reversed it, arguing that Morrissey-Berru was not in line with the exemption since she did not have a formal ministerial title. Additionally, she had no formal religious training and never held herself as a respectable religious leader (JD Supra, 2020). On the other end, Biel stated that St. James discharged her from performing her duties since she requested leave to receive cancer treatment (Harvard Law Review, 2020). Similar to OLG, St. James acquired a summary judgment in association with ministerial exception (Harvard Law Review, 2020). The Ninth Circuit reversed, arguing that Biel had no formal title of a minister and lacked ministerial background.
Outcome
The court held that the employment discrimination claims for the two teachers at the Catholic schools overall qualified for the Hosanna-Tabor exception. In other words, although both elementary teachers had no formal title of a minister and limited religious training, the religious education and formation of students were the basic reason for the existence of the majority of religious schools (JD Supra, 2020). The selection and supervision of teachers for respective schools, in one way or the other, subjected them to perform the mission spelled out (Harvard Law Review, 2020). The court highlighted that the judicial review in a manner in which religious institutions performed their duties would have limited independence of these schools in a way that First Amendment does not allow.
Opinion
First of all, I think it was completely unfair and unreasonable for the religious institutions to fire the two elementary schools for, among others, the ministerial duties they relied on. It makes no sense to think that school teachers should be expected to hold ministerial titles; however, they are still performing their duties as prescribed in their employment contract. I strongly agree with the Supreme Court’s final ruling that religious institutions should not have fired the teachers for reasons that were not directly related to their work. In reality, the schools requested the teachers to teach religious education only to be disqualified and fired afterward. I am of the opinion that in case such a ruling is not reversed, in the near future, there could create chaos, especially among religious institutions that could look for petty reasons to dismiss employees.
References
Harvard Law Review. (2020). Our Lady of Guadalupe School v. Morrissey-Berru.
JD Supra. (2020). Supreme Court decides Our Lady of Guadalupe School v. Morrissey-Berru.