E-Alert Case Updates
Wrongful Termination Claim by Minister Barred by Ministerial Exception
Edwin R. Melhorn v. Baltimore Washington Conference of the United Methodist Church, et al.
In a recent unreported opinion, the Court of Special Appeals held that the First Amendment’s “ministerial exception” barred courts from considering the merits of a wrongful termination claim asserted against a church even though the claim was not specifically predicated on matters of religious doctrine.
Beginning in 2009, Plaintiff, Edwin R. Melhorn, was employed as a pastor at Cedar Grove United Methodist Church, a church governed by the Baltimore-Washington Conference of the United Methodist Church (collectively, “Defendants”). On October 16, 2012, Defendants informed Plaintiff that they were terminating his employment because they had “lost faith” in his spiritual leadership.
Subsequently, Plaintiff filed a wrongful termination lawsuit against Defendants, alleging that he was discharged because he refused to commit unlawful acts in connection with the administration of a trust of which Cedar Grove was a beneficiary. Specifically, Plaintiff averred that, on May 16, 2012, Cedar Grove was informed that it was scheduled to receive a bequest of over $1.2 million from a trust. Under the terms of the trust, half of that amount was to be used for the operation of the church, and the other half was to be used for the upkeep of a cemetery maintained by the church. Cedar Grove, however, had sold its cemetery. Consequently, Plaintiff informed the church that it would be a breach of trust, fraud, and tax evasion to accept the half of the trust bequeathed for the purposes of the cemetery’s upkeep. Despite Plaintiff’s advice, Cedar Grove instructed Plaintiff to request the full amount of the bequest. Plaintiff refused to do so, and in August of 2012 he informed the Baltimore-Washington Conference of his concerns. Two months later, he was informed that his employment was terminated.
Defendants moved to dismiss Plaintiff’s complaint, asserting that the First Amendment’s ministerial exception bars courts from hearing disputes over church doctrines. In this case, Defendants argued that courts would necessarily be required to ascertain the veracity of Defendants’ statement that Plaintiff was fired because they lost faith in his spiritual leadership. The trial court agreed and dismissed the complaint. Plaintiff appealed.
The Court of Special Appeals affirmed. Judge Reed, writing for the Court, explained that there are two elements that must be shown in order for the ministerial exception to apply: (1) the employee making the claim must be a minister; and (2) “the claim must be the type of claim which would substantially entangle the court in the church’s doctrinal decision-making and internal self-governance.” In this case, it was undisputed that Plaintiff was a minister.
As to the second element of the exception, the intermediate appellate court was persuaded that Plaintiff’s claim would involve an entanglement with Defendants’ doctrinal decision-making. Under Maryland law, the ministerial exception is somewhat broader than the Supreme Court’s holding in Hosanna-Tabor Evangelical Lutheran Church & Sch. v. E.E.O.C., 132 S. Ct. 694 (2012). Specifically, the Court of Appeals has applied the doctrine to wrongful termination claims, whereas the Supreme Court has only applied it in the context of employment discrimination claims. In so doing, Maryland has embraced the concept that “religious organizations must be allowed to hire and fire their clergy members without government interference.” In this case, the Court of Special Appeals believed that it would be impossible to adjudicate Plaintiff’s claims without addressing Defendants’ position that Plaintiff was fired due to Defendants’ lack of faith in his spiritual leadership. Accordingly, the Court of Special Appeals affirmed the trial court’s decision that the ministerial exception barred Plaintiff’s lawsuit.
The Court also rejected Plaintiff’s argument that he should be permitted to conduct discovery prior to any ruling on Defendants’ motion to dismiss. In contrast to cases from other jurisdictions that had held discovery was permissible under similar circumstances, in this case, the question of Plaintiff’s termination would necessarily involve inquiry into religious matters. Because, on its face, Plaintiff’s claim involved such matters, no discovery was warranted.
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