The decision explicitly left open the question of whether religious organizations could be sued for other reasons: "We express no view on whether the exception bars other types of suits, including actions by employees alleging breach of contract or tortious conduct".

Justice Samuel Alito wrote a concurring opinion, which Elena Kagan joined, stating that the word "minister" used in the decision should extend to similar titles for other religions such as rabbi for Judaism or imam in Islam.

In a press release, a spokesperson for the organization stated: "We are pleased that the Supreme Court rejected the Obama administration's profoundly troubling claim of power over churches, and glad to see that the Supreme Court has stayed out of the Lutheran Church's affairs and allowed its internal rules as a body of believers to stand.

In her brief, Ms. Perich warned that expanding the ministerial exception to include workers like her would allow a religious organization, for example, to retaliate against a teacher for reporting sexual abuse of a student to the government.

[8]In 2014, the Archdiocese of Cincinnati ordered its 2,000 teachers regardless of religion to sign a "detailed morality clause" that critics say focuses on "pelvic issues."

The new contracts forbid teachers from living together, having sex outside of marriage, using in-vitro fertilization or surrogacy, exhibiting a gay "lifestyle" or any speech expressing support for these things.