Title VII "Ministerial Exception" Does Not Apply to Technology Teacher in Catholic School
1 min read
Apr 5, 2012
A federal district court in Ohio has found that Title VII's "ministerial exception" does not apply to a non-Catholic technology teacher at a Catholic school. The Ohio case, Dias v. Archdiocese of Cincinnati, et al., was one of the first to analyze the ministerial exception following the U.S. Supreme Court's January 2012 ruling that the exception applied to a teacher at a Lutheran school in Hosanna-Tabor Church v. Equal Employment Opportunity Commission.
The Ohio case involved a technology teacher at a Catholic school who was terminated after her employer learned that she had become impregnated by artificial insemination. The teacher sued for discrimination on the basis of pregnancy under Title VII and the Pregnancy Discrimination Act. The Archdiocese of Cincinnati argued that she fell within the "ministerial exception" based upon her inherent role as a model of Catholic values for students. The federal court rejected that argument for two reasons. First, the court found important differences between the case before it and the facts of Hosanna-Tabor -- where the Lutheran teacher in that case had felt that she was"called" to her position by God, taught religious education, led worship, and studied in a theological program; here, the technology teacher did not teach any religion, did not participate in any worship, and, in fact, was not even Catholic herself. Second, the Ohio court found, the teacher's status as an educator in a Catholic school and alleged duty to act as a Catholic role model was not sufficient to make her a "minister"; such a rule, the court found, "would create an exception capable of swallowing up the rule."
This decision is helpful to religious employers who are concerned about the scope of the ministerial exception. The case shows that, even after Hosanna-Tabor, real ministerial activities and status are still necessary to in order to claim the exception. Religious employers should expect that all employees will continue to be protected by nondiscrimination laws unless there is strong evidence that the employee is actually a religious minister. Hinshaw will keep tabs on this issue, as it will surely develop in further cases.
Topics
Featured Insights

Event
Apr 23, 2026
Driving Ahead: Insights from Industry Leaders Auto Finance Seminar

Consumer Crossroads: Where Financial Services and Litigation Intersect
Mar 13, 2026
DOJ Settlement with Car Retailer Highlights SCRA Repossession Risks

Privacy, Cyber & AI Decoded Alert
Mar 11, 2026
Compliance Considerations for GDPR Consent in Biotech Clinical Research

Press Release
Mar 4, 2026
Marcia Mueller Named the 2026 Mentorship Award Winner by YWCA Northwestern Illinois

Press Release
Mar 3, 2026
Hinshaw Announces New Administrative Leadership Appointments

In The News
Feb 27, 2026
Hinshaw Partners Examine Implications for Nursing Homes of New Illinois Aid-in-Dying Law

In The News
Feb 24, 2026
Lucy Wang Authors Law360 “Expert Analysis” on Why Attorney Civility Means More in 2026

Press Release
Feb 13, 2026
Hinshaw Team Wins Appeal in Criminal Indictment of Waukegan City Clerk Janet Kilkelly

Press Release
Feb 10, 2026
Hinshaw Trial Team Secures $0 Defense Verdict in $15 Million Auto Accident Trial

Press Release
Feb 5, 2026
Hinshaw Legal Team Secures Directed Verdict in Florida Equine Fraud Case

Press Release
Feb 4, 2026
Hinshaw Celebrates 17 Consecutive Years of Being Named an Equality 100 Award Winner
![[Video] New Regulatory Priorities Under Mayor Mamdani’s NYC Department of Consumer and Worker Protection](/a/web/oHiTWa7kRy3Ht1brq6k4BT/bkMx39/new-york-city-skyline.jpg)
