Yves Conseant, a former French teacher at St. Louis University High School, a Catholic school, filed a lawsuit, alleging that the School discriminated against him based on his race and in retaliation for engaging in protected conduct, with such discrimination resulting in the School terminating his employment.
The School moved for summary judgment based on the ministerial exception, which prohibits courts from intervening in employment disputes involving ministerial leaders. The U.S. Supreme Court expanded the ministerial exception to lay teachers with religious duties and that played a vital role in carrying out the core mission of the church.
Here, the Court concluded the ministerial exception applied to Conseant’s claims.
In particular, the School’s Faculty and Staff Handbook notes that every member of the faculty and staff is required to actively participate in effectuating the religious mission of the School. As stated in the Handbook, faculty are encouraged to attend morning mass, parent-son liturgies, family masses, class prayer services, and retreats. The Handbook also sets forth professional standards expected of the teachers, including maintaining positive attitudes towards the formation of “men and women for others,” and teaching as ministry. The Handbook notes that the School may give more favorable consideration to Roman Catholic applicants over non-Roman Catholic applicants when making hiring decisions, and notes that employees must respect Catholic values and Jesuit traditions.
The Court also considered the employment agreement that Conseant signed, which included language that the employee was committed to the goals and ideals of Jesuit education, as stated in the School’s Faculty and Staff Handbook. In the agreement, Conseant agreed to perform his job duties with professionalism, in accordance with the School’s stated philosophy and Faculty and Staff Handbook.
Finally, the Court considered Conseant’s actual work at the School. As a faculty member, Conseant was required to attend all-school masses and participate in the School’s daily prayer exercises. Notes from observations made during Conseant’s classes indicated that Conseant involved his students in prayer and prepared them for Mass during class, often having the students pray and sing Catholic hymns in French.
The Court concluded that the Ministerial Exception applied to Conseant and granted summary judgment to the School.
Conseant v. St. Louis Univ. High Sch. (E.D.Mo. July 25, 2024) 2024 U.S.Dist.LEXIS 131595.
Note: This case shows the types of details that courts will consider when analyzing the Ministerial Exception, such as the School’s handbook, the signed employment agreement, and the employee’s actual work.