(Los Angeles, CA) Frances Atkins had been a dedicated employee at St. Cecilia Catholic School for a significant period of time. In her final year with the school, she held part-time positions as both an art teacher and an office administrator. However, following the termination of her employment, Atkins took legal action against the school, alleging age discrimination in violation of the California Fair Employment and Housing Act.
Initially, the trial court ruled in favor of the school, granting summary judgment based on the application of the ministerial exception. This exception prevents certain employment claims from being brought against a religious institution by its “ministers.” However, the Court of Appeal later overturned the decision. The Court held that even though the school did not explicitly assert the ministerial exception as an affirmative defense, there were significant factual issues that needed to be examined regarding whether the exception should apply to Atkins’ position.
It was noted that Atkins did not teach religion to the students, nor did she lead them in any religious activities or services. She had never attended such services herself. Despite occasionally praying with the students in her art class and promoting the Archdiocese of Los Angeles’ six tasks of catechesis by encouraging “Christ-like” behavior, there were still factual disputes regarding whether educating students in the Catholic faith was a central part of her job responsibilities. This was especially relevant as she held dual roles as both a teacher and a school administrator.
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