Courts adjudicating employment disputes under employment statutes will decline to do so where inquiry into the employment relationship will interfere with First Amendment religious protections. Often, this concerns a claim challenging the legality of termination of a member of the clergy, but the concept can also extend to such employees’ claims under wage-and-hour laws, as exemplified in a new decision. Matthies v. First Presbyterian Church of Greensburg Ind., Inc., 2015 Ind. App. LEXIS 293 (Ind. Ct. App. Apr. 8, 2015).

In Matthies, the Plaintiff was a reverend whose relationship with his parish deteriorated, until ultimately the church concluded that the employment relationship “need[ed] to be ended in order to prevent further deterioration of the spiritual health of the church.” After his separation the reverend brought claims under, inter alia, the Indiana Wage Claims Statute seeking to recover unpaid vacation wages. Because to “address . . . competing positions regarding the facts” would “require a court to inquire into the religious doctrine of the Presbyterian Church and its polity,” the Court of Appeals upheld the trial court’s decision declining to do so in order to preserve the church’s freedom of religion and avoid a scenario where it would be called upon to “apply religious doctrine or ecclesiastical law.”

Religious organizations must assess the scope of the applicability of the ministerial exception to their employees, as well as their compliance with employment statutes generally.