PATRICIA DAYNER v. ARCHDIOCESE OF HARTFORD et al., SC 18468
Judicial District of Hartford
Constitutional Law; Free Exercise Clause; Whether a Parochial School Principal's Action Against the Archdiocese of Hartford was Barred by the "Ministerial Exception" to Judicial Authority. The plaintiff served as the principal of a parochial school that was run by the Archdiocese of Hartford. After the archdiocese declined to renew her employment contract, the plaintiff initiated the present action against the archdiocese and the pastor of the school, alleging, among other things, that her employment was terminated because she had refused to retaliate against a student who had asserted that the pastor had made inappropriate remarks during a religious education class that he taught. The defendants filed a motion to dismiss the action, claiming that the trial court lacked subject matter jurisdiction pursuant to the free exercise clause of the first amendment to the United States constitution. In doing so, they invoked the "ministerial exception" to judicial authority, which precludes courts from adjudicating employment disputes between religious institutions and their religious leaders. In denying the motion, the trial court determined that the plaintiff's claims involved discrete inquiries that would not intrude upon purely religious matters or issues relating to church governance. It reasoned that the plaintiff's common-law contract and tort claims merely alleged, among other things, that (1) the plaintiff was denied her contractual right under the policies of the Office of Catholic Education to address her purported performance deficiencies and cure them in a timely manner; and (2) her employment was terminated as a result of her failure to "stick up for" the school's pastor in connection with the controversy concerning his allegedly inappropriate remarks. The resolution of these claims, the court opined, would not require any intrusion into religious doctrine or practices. In this appeal, the defendants argue that because the plaintiff was a ministerial employee of the school in that she was important to the religious mission of the church, the trial court lacked jurisdiction over her lawsuit regardless of whether her specific claims implicated matters of religion. They also contend, among other things, that the plaintiff's claims did, in fact, involve religious practices and church governance.