March 8, 2021
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Posted on Fair Work

In a landmark decision, the Massachusetts Supreme Judicial Court ruled in DeWeese-Boyd v. Gordon College that the "ministerial exception" does not apply to an associate professor of social work at Gordon College, a private Christian liberal arts institution. The ministerial exception shields religious institutions from certain employment discrimination claims involving ministerial employees – but the Court deemed that exception inapplicable in this case.

The Court affirmed that Gordon College qualifies as a religious institution due to its commitment to Christian principles and its mission to integrate faith into education.​ However, the Court concluded that DeWeese-Boyd was not a ministerial employee and could therefore pursue her discrimination claims against the College. While she was required to integrate Christian faith into her teaching and scholarship, DeWeese-Boyd's role did not involve traditional ministerial duties such as teaching religion, leading prayers, conducting chapel services, or engaging in religious rituals like a true "minister."​

Though theCourt also emphasized a functional analysis of DeWeese-Boyd’s role rather than relying on mere labels, the Court also found that her title as "associate professor of social work" and her lack of formal religious ordination or commissioning further supported the Court’s decision. In so holding, the Court rejected Gordon College’s argument that all faculty members should be considered ministers under the exception. Expanding the exception to this extent, the Court concluded, would significantly erode civil law protections against workplace discrimination.​

DeWeese-Boyd is represented by Hillary Schwab of Fair Work P.C.

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