Key Cases Church Autonomy Ministerial Exception Doctrine Bars Minister-on-Minister Hostile Work Environment Claim In Demkovich v. St. Andrew the Apostle Parish, Calumet City , No. 19-2142, 2021 WL 2880232 (7th Cir. July 9, 2021), the U.S. Court of Appeals for the Seventh Circuit ruled on interlocutory appeal that the ministerial exception doctrine applies to hostile work environment claims based on minister-on-minister harassment. A circuit split already exists on the question. The Seventh Circuit joined the Tenth Circuit, but the Ninth Circuit held that the doctrine does not cover hostile work environment claims at least as a categorical matter. The plaintiff was the music director, choir director and organist for St. Andrew the Apostle Parish, a Roman Catholic Church. Rev. Jacek Dada, a Catholic priest and the church’s pastor, supervised the plaintiff and eventually terminated him. The plaintiff complained that Rev. Dada repeatedly subjected him to derogatory comments and demeaning epithets showing a discriminatory animus toward his sexual orientation. After the plaintiff married his partner, contrary to Catholic teachings, Rev. Dada asked for his resignation. The district court ruled that the ministerial exception doctrine was not a categorical ban to the plaintiff’s claims premised upon intangible employment action, but applied […]
