Our Lady of Guadalupe School v. Morrissey-Berru, 591 U.S. ___ (2020), was a United States Supreme Court case involving the ministerial exception of federal employment discrimination laws.
The case extends from the Supreme Court's prior decision in Hosanna-Tabor Evangelical Lutheran Church & School v. Equal Employment Opportunity Commission[1] which created the ministerial exception based on the Establishment and Free Exercise Clauses of the United States Constitution, asserting that federal discrimination laws cannot be applied to leaders of religious organizations.
The Supreme Court ruled in a 7–2 decision on July 8, 2020 that reversed the Ninth Circuit's ruling, affirming that the principles of Hosanna-Tabor, that a person can be serving an important religious function even if not holding the title or training of a religious leader, satisfied the ministerial exception in employment discrimination.
[3] Biel filed notice with the Equal Employment Opportunity Commission (EEOC), believing her termination violated the Americans with Disabilities Act (ADA), and the EEOC gave her authorization to sue the school in the United States District Court for the Central District of California.
The District Court issued summary judgement for St. James on the basis that Biel's position fell into that covered by Hosanna-Tabor as ministerial and thus immune from discrimination laws.
[8] Oral arguments were heard via teleconference on May 11, 2020, part of the block of cases held in this manner due to the COVID-19 pandemic.
[3] The Court issued its decision on July 8, 2020,[9] reversing the Ninth Circuit's ruling in both consolidated cases and remanding them for review.
In the 7–2 majority opinion written by Justice Samuel Alito and joined by all but Justices Ruth Bader Ginsburg and Sonia Sotomayor, the Court ruled that the Ninth had erred in applying the four Hosanna-Tabor conditions that must all be met to evoke the ministerial exception, and instead should be based primarily on the religious function that the position serves within the organization.