Our Lady of Guadalupe School v. Morrissey-Berru

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Supreme Court of the United States
Our Lady of Guadalupe School v. Morrissey-Berru
Term: 2019
Important Dates
Argument: May 11, 2020
Decided: July 8, 2020
Outcome
Reversed and remanded
Vote
7-2
Majority
Samuel Alito • Chief Justice John G. Roberts • Stephen Breyer • Elena Kagan • Brett Kavanaugh
Concurring
Clarence Thomas • Neil Gorsuch
Dissenting
Sonia Sotomayor • Ruth Bader Ginsburg


Our Lady of Guadalupe School v. Morrissey-Berru is a case argued before the Supreme Court of the United States on May 11, 2020, during the court's October 2019-2020 term. The case came on a writ of certiorari to the United States Court of Appeals for the 9th Circuit.[1] The case was consolidated with St. James School v. Biel.[2][3]

Oral argument was initially scheduled for April 1, 2020. However, the U.S. Supreme Court announced on March 16 that it was postponing the 11 oral arguments originally scheduled during its March sitting. In a press release, the court said the delay was "in keeping with public health precautions recommended in response to COVID-19."[4] COVID-19 was the abbreviation for coronavirus disease 2019, caused by SARS-CoV-2. On April 15, the court announced it had rescheduled the case for May 11, 2020.

  • Click here for more information about the court's response to the coronavirus pandemic.
  • Click here for more information about political responses to the pandemic.

The court reversed and remanded the decision of the United States Court of Appeals for the 9th Circuit in a 7-2 ruling, holding that the First Amendment's religion clauses foreclose the adjudication of Morrissey-Berru and Biel's employment discrimination claims.[5] Click here for more information.

HIGHLIGHTS
  • The case: In both cases, two teachers at Catholic schools were not offered contract renewals. Both teachers filed discrimination claims in federal district court against their former employers. The court ruled that both schools were protected religious organizations exempted from anti-discrimination employment laws. Both teachers appealed to federal circuit court, which reversed the district court's ruling in one case and denied petition for rehearing and for rehearing en banc in the second case. Click here for more details about Our Lady of Guadalupe School v. Morrissey-Berru and here for more information about St. James School v. Biel.
  • The issue: Whether the religion clauses prevent civil courts from adjudicating employment discrimination claims brought by an employee against her religious employer, where the employee carried out important religious functions.[6]
  • The outcome: The court reversed and remanded the decision of the 9th Circuit in a 7-2 ruling, holding that the First Amendment's religion clauses foreclose the adjudication of Morrissey-Berru and Biel's employment discrimination claims.[5]


    • You can review the lower court's opinion for Our Lady of Guadalupe School v. Morrissey-Berru here and for St. James School v. Biel here.[7][8]

    Timeline

    The following timeline details key events in Our Lady of Guadalupe School v. Morrissey-Berru:

    • July 8, 2020: The U.S. Supreme Court reversed and remanded the decision of the 9th Circuit in a 7-2 opinion.
    • May 11, 2020: Oral argument
    • March 16, 2020: The U.S. Supreme Court postponed its March sitting. Oral arguments in this case were initially scheduled for April 1, 2020.
    • December 18, 2019: The U.S. Supreme Court agreed to hear the case. The case was consolidated with St. James School v. Biel.
    • August 28, 2019: Our Lady of Guadalupe School filed a petition with the U.S. Supreme Court.
    • April 30, 2019: The United States Court of Appeals for the 9th Circuit reversed the United States District Court for the Central District of California's ruling.

    The following timeline details key events in St. James School v. Biel:

    • December 18, 2019: The U.S. Supreme Court agreed to hear the case. The case was consolidated with Our Lady of Guadalupe v. Morrissey-Berru.
    • September 16, 2019: St. James School filed a petition with the U.S. Supreme Court.
    • June 25, 2019: The United States Court of Appeals for the 9th Circuit denied the petitions for rehearing and for rehearing en banc.


    Background

    Procedural background

    Our Lady of Guadalupe School v. Morrissey-Berru

    In 1999, Agnes Deirdre Morrissey-Berru became a full-time teacher at a Catholic parochial school, Our Lady of Guadalupe School. She taught fifth and sixth-grade classes over the course of her tenure. Her responsibilities included incorporating religious doctrine and worship into her teaching practice.[7]

    In 2012, a catechist certification requirement was implemented for Our Lady of Guadalupe School teachers as part of a new, school-wide reform process to prevent the school's closure. The parish hired a new principal, April Beuder, who required all teachers to attain the catechist certification and to adopt a new reading program. The school asserted that Morrissey-Berru did not fully implement the new program requirements in the 2012-2013 school year. Morrissey-Berru's offer for contract renewal for the 2013-2014 school year was conditioned by the school on fully implementing the new program. The school asserted that Morrissey-Berru did not fulfill the condition during the term of her 2013-2014 contract. Morrissey-Berru was moved to a part-time position that was not subject to the new program requirements. In May 2015, Beuder informed Morrissey-Berru that a new contract would not be offered for the 2015-2016 school year. In its petition to the U.S. Supreme Court, the school wrote that the decision was made in part due to budgetary issues. In June after her teaching contract was terminated, Morrissey-Berru filed an age discrimination claim against Our Lady of Guadalupe School.[7][9]

    Below is a brief timeline of the litigation in Our Lady of Guadalupe School v. Morrissey-Berru:

    • 2015: In June, Morrissey-Berru filed an age discrimination claim against Our Lady of Guadalupe School under the Age Discrimination in Employment Act after her teaching contract was terminated.
    • 2016: In December, Morrissey-Berru filed a complaint against the school for age discrimination in federal district court.
    • 2017: In August, Our Lady of Guadalupe School filed a motion for summary judgment.[10] The district court granted the motion and ruled that Morrissey-Berru's claim was barred by ministerial exception to the First Amendment, which exempts religious organizations from anti-discrimination employment laws. The court ruled that Morrissey-Berru qualified as a minister due to her role and responsibilities as a teacher with Our Lady of Guadalupe School.
    • 2019: Morrissey-Berru appealed to the Ninth Circuit. The court reversed the district court's rulings, holding that Morrissey-Berru's duties and her official title of teacher did not meet the standard required for ministerial exception.


    St. James School v. Biel

    In 2013, Kristen Biel became a full-time fifth-grade teacher at a Catholic parochial school, St. James School. Her responsibilities included demonstrating her religious beliefs and actively engaging in school events focused on worship.[8]

    In the 2013-2014 school year, Biel had her only performance review. The evaluation was positive and included notes for improvement. In its petition to the U.S. Supreme Court, St. James School wrote that school principal Sister Mary Margaret Kreuper noticed that Biel's classroom was disorderly and did not improve following her review.[8][11][12]

    Less than six months later, Biel was diagnosed with breast cancer. In April 2014, Biel informed Kreuper that she would miss work to undergo treatment of surgery and chemotherapy and that May 22 would be her last day teaching. In its Supreme Court filing, St. James School wrote that Kreuper expressed sympathy and said that she was currently undergoing treatment for breast cancer. A few weeks later, Biel was informed her teaching contract would not be renewed for the 2014-2015 school year. In December, Biel filed suit against the school, alleging that her termination violated the Americans with Disabilities Act (ADA).[8][11]

    Biel passed away on June 7, 2019. Her husband Darryl Biel, in his capacity as the personal representative of her estate, was substituted as the plaintiff-appellant in the case before the Supreme Court.[11]

    Below is a brief timeline of the litigation in St. James School v. Biel:

    •  2014: In December, Biel filed charges with the Equal Employment Opportunity Commission against St. James School claiming that her termination violated the ADA.
    •  2015: In March, Biel was issued a right-to-sue letter by the Equal Employment Opportunity Commission. Then, Biel filed suit in federal district court against St. James School. St. James School filed a motion for summary judgment.[10] The district court granted the school's motion and ruled that Biel's claim was barred by ministerial exception to the First Amendment. The court ruled that Biel qualified as a minister due to her role and responsibilities as a teacher with St. James School.
    • 2018: Biel appealed to the Ninth Circuit. A divided panel of the Ninth Circuit reversed the district court's rulings, holding that Biel's duties did not meet the standard required for ministerial exception.
    • 2019: St. James School filed a petition for rehearing en banc with the Ninth Circuit. The court denied the petition.

    Legal definitions

    Ministerial exception

    The following quote is from the U.S. Court of Appeals for the Ninth Circuit's opinion in the case Our Lady of Guadalupe School v. Morrissey-Berru:[7]

    “ In Hosanna-Tabor Evangelical Lutheran Church & School v. EEOC, the Supreme Court recognized the ministerial exception for the first time, 565 U.S. 171, 188 (2012), and considered the following four factors in analyzing whether the exception applied: (1) whether the employer held the employee out as a minister by bestowing a formal religious title; (2) whether the employee's title reflected ministerial substance and training; (3) whether the employee held herself out as a minister; and (4) whether the employee's job duties included "important religious functions," id. at 191-92. Hosanna expressly declined to adopt "a rigid formula for deciding when an employee qualifies as a minister," and instead considered "all the circumstances of [the employee's] employment." Id. at 190.[13] ”

    Questions presented

    The petitioner presented the following questions to the court:[6]

    Questions presented:
    • Whether the religion clauses prevent civil courts from adjudicating employment discrimination claims brought by an employee against her religious employer, where the employee carried out important religious functions.

    Outcome

    In a 7-2 opinion, the court reversed and remanded the decision of the United States Court of Appeals for the 9th Circuit, holding that the First Amendment's religion clauses foreclose the adjudication of Morrissey-Berru and Biel's employment discrimination claims. Justice Samuel Alito delivered the opinion of the court. Justice Clarence Thomas filed a concurring opinion, joined by Justice Neil Gorsuch. Justice Sonia Sotomayor filed a dissenting opinion, joined by Justice Ruth Bader Ginsburg.[5]

    Opinion

    In his opinion, Justice Samuel Alito wrote:[5]

    “ These cases require us to decide whether the First Amendment permits courts to intervene in employment disputes involving teachers at religious schools who are entrusted with the responsibility of instructing their students in the faith. The First Amendment protects the right of religious institutions "to decide for themselves, free from state interference, matters of church government as well as those of faith and doctrine.” Kedroff v. Saint Nicholas Cathedral of Russian Orthodox Church in North America, 344 U.S. 94, 116 (1952). Applying this principle, we held in Hosanna-Tabor Evangelical Lutheran Church and School v. EEOC, 565 U.S. 171 (2012), that the First Amendment barred a court from entertaining an employment discrimination claim brought by an elementary school teacher, Cheryl Perich, against the religious school where she taught. Our decision built on a line of lower court cases adopting what was dubbed the "ministerial exception" to laws governing the employment relationship between a religious institution and certain key employees. We did not announce “a rigid formula” for determining whether an employee falls within this exception, but we identified circumstances that we found relevant in that case, including Perich's title as a "Minister of Religion, Commissioned," her educational training, and her responsibility to teach religion and participate with students in religious activities. Id., 190–191.


    In the cases now before us, we consider employment discrimination claims brought by two elementary school teachers at Catholic schools whose teaching responsibilities are similar to Perich's. Although these teachers were not given the title of "minister" and have less religious training than Perich, we hold that their cases fall within the same rule that dictated our decision in Hosanna-Tabor. The religious education and formation of students is the very reason for the existence of most private religious schools, and therefore the selection and supervision of the teachers upon whom the schools rely to do this work lie at the core of their mission. Judicial review of the way in which religious schools discharge those responsibilities would undermine the independence of religious institutions in a way that the First Amendment does not tolerate.[13]

    		”
    —Justice Samuel Alito

    Concurring opinion

    Justice Clarence Thomas filed a concurring opinion, joined by Justice Neil Gorsuch.[5]

    In his concurring opinion, Justice Thomas wrote:

    “ I agree with the Court that Morrissey-Berru’s and Biel’s positions fall within the "ministerial exception," because, as Catholic school teachers, they are charged with "carry[ing] out [the religious] mission" of the parish schools. Ante, at 21. The Court properly notes that “judges have no warrant to second-guess [the schools'] judgment" of who should hold such a position "or to impose their own credentialing requirements." Ante, at 24. Accordingly, I join the Court's opinion in full. I write separately, however, to reiterate my view that the Religion Clauses require civil courts to defer to religious organizations’ good-faith claims that a certain employee’s position is “ministerial.” (See Hosanna-Tabor Evangelical Lutheran Church and School v. EEOC, 565 U.S. 171, 196 (2012) (Thomas, J., concurring).


    ... The Court’s decision today is a step in the right direction. The Court properly declines to consider whether an employee shares the religious organization’s beliefs when determining whether the employee's position falls within the "ministerial exception," explaining that to "determin[e] whether a person is a 'co-religionist' . . . would risk judicial entanglement in religious issues." Ante, at 26. But the same can be said about the broader inquiry whether an employee's position is "ministerial."

    ... As this Court has explained, the Religion Clauses do not permit governmental "interfere[nce] with . . . a religious group's right to shape its own faith and mission through its appointments." Hosanna-Tabor, supra, at 188. To avoid such interference, we should defer to these groups' good-faith understandings of which individuals are charged with carrying out the organizations’ religious missions.[13]

    		”
    —Justice Clarence Thomas

    Dissenting opinion

    Justice Sonia Sotomayor filed a dissenting opinion, joined by Justice Ruth Bader Ginsburg.[5]

    In her dissent, Justice Sotomayor wrote:[5]

    “ Two employers fired their employees allegedly because one had breast cancer and the other was elderly. Purporting to rely on this Court's decision in Hosanna-Tabor Evangelical Lutheran Church and School v. EEOC, 565 U.S. 171 (2012), the majority shields those employers from disability and age-discrimination claims. In the Court's view, because the employees taught short religion modules at Catholic elementary schools, they were "ministers" of the Catholic faith and thus could be fired for any reason, whether religious or nonreligious, benign or bigoted, without legal recourse. The Court reaches this result even though the teachers taught primarily secular subjects, lacked substantial religious titles and training, and were not even required to be Catholic. In foreclosing the teachers' claims, the Court skews the facts, ignores the applicable standard of review, and collapses Hosanna-Tabor’s careful analysis into a single consideration: whether a church thinks its employees play an important religious role. Because that simplistic approach has no basis in law and strips thousands of school-teachers of their legal protections, I respectfully dissent.


    ... This sweeping result is profoundly unfair.The Court is not only wrong on the facts, but its error also risks upending anti-discrimination protections for many employees of religious entities. Recently, this Court has lamented a perceived "discrimination against religion." E.g. Espinoza v. Montana Department of Revenue, ante, at 12. Yet here it swings the pendulum in the extreme opposite direction, permitting religious entities to discriminate widely and with impunity for reasons wholly divorced from religious beliefs. The inherent injustice in the Court's conclusion will be impossible to ignore for long, particularly in a pluralistic society like ours. One must hope that a decision deft enough to remold Hosanna-Tabor to fit the result reached today reflects the Court’s capacity to cabin the consequences tomorrow. ...[13]

    		”
    —Justice Sonia Sotomayor

    Text of the opinion

    Read the full opinion here.

    Oral argument

    Audio

    Audio of oral argument:[14]



    Transcript

    See also

    External links

    Footnotes

    1. ↑ SCOTUSblog, "Our Lady of Guadalupe School v. Morrissey-Berru," accessed December 18, 2019
    2. ↑ St. James School v. Biel came on a writ of certiorari to the United States Court of Appeals for the 9th Circuit. The docket number is 19-348.
    3. ↑ SCOTUSblog, "St. James School v. Biel," accessed December 18, 2019
    4. ↑ U.S. Supreme Court, "Press release from March 16, 2020," accessed March 16, 2020
    5. ↑ 5.0 5.1 5.2 5.3 5.4 5.5 5.6 Supreme Court of the United States, Our Lady of Guadalupe School v. Morrissey-Berru, decided July 8, 2020
    6. ↑ 6.0 6.1 Supreme Court of the United States, "19-267 Our Lady of Guadalupe School v. Morrissey-Berru questions presented," accessed July 8, 2020
    7. ↑ 7.0 7.1 7.2 7.3 United States Court of Appeals for the Ninth Circuit, "Morrissey-Berru v. Our Lady of Guadalupe Sch.," accessed December 18, 2019
    8. ↑ 8.0 8.1 8.2 8.3 United States Court of Appeals for the Ninth Circuit, "Biel v. St. James Sch.," accessed December 18, 2019
    9. ↑ Supreme Court of the United States, "Petition for a writ of certiorari," accessed December 20, 2019
    10. ↑ 10.0 10.1 Cornell Law School Legal Information Institute, "Summary judgment," accessed December 20, 2019
    11. ↑ 11.0 11.1 11.2 Supreme Court of the United States, "Petition for a writ of certiorari," accessed December 20, 2019
    12. ↑ United States Court of Appeals for the Ninth Circuit, "Opinion," filed December 17, 2018
    13. ↑ 13.0 13.1 13.2 13.3 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    14. ↑ Supreme Court of the United States, "Oral Argument - Audio," accessed May 18, 2020
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