Fired Pastor’s Contract Suit Dismissed Under Ministerial Exception and Excessive Entanglement Doctrines
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In Lee v. Sixth Mount Zion Baptist Church of Pittsburg, (WD PA, Aug. 22, 2017), a Pennsylvania federal district court dismissed a breach of contract claim brought by a pastor against the church that had terminated his employment. Rev. William Lee claims that the church breached his contract by not compensating him under the clause relating to termination without cause. the church argued that Lee was terminated for failing to fulfill his duties and responsibilities under the contract. The court dismissed on ministerial exception and excessive entanglement grounds, saying in part:[T]he “ministerial exception” recognizes the right of a religious institution in exercising its First Amendment guarantee of religious liberty and autonomy in matters ecclesiastical to terminate from employment a Pastor such as Rev. Lee. Rev. Lee’s dispute with the Church regarding his termination from employment fully implicates such rights….The Church argues that where Rev. Lee failed in spiritual stewardship, financial stewardship and responsiveness to Church leadership, as determined by the Church and its Congregation, his termination was for cause under § 12.3…. [T]he Court concludes that any determination whether Rev. Lee failed in his spiritual and financial stewardship and responsiveness to Church leaders is a matter best left to the Church alone. Otherwise, the Court and jury would need to probe how the Church evaluated spiritual success and leadership under its doctrine…. Prohibited considerations of ecclesiastical hierarchy are directly implicated in the assessment that Rev. Lee did not adequately respond to Church leadership.