Wash. Supreme Court published opinion — 961328.pdf

Citation: Wash. Supreme Court published opinion — 961328.pdf
Jurisdiction: Washington (state)
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Original Source: https://www.courts.wa.gov/opinions/pdf/961328.pdf ↗

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doctrine, or ecclesiastical governance, so that we do not meddle or undermine the

independence of religious institutions.

The ministerial exception, required by both religion clauses of the First

Amendment, is a guide that will help courts “stay out of employment disputes

involving those holding certain important positions with churches and other

religious institutions.” Id. at 2060. Whether a particular employment position

4
For the current opinion, go to https://www.lexisnexis.com/clients/wareports/.
Woods v. Seattle’s Union Gospel Mission, No. 96132-8
(Yu, J., concurring)

qualifies as “ministerial” is a question of law, and in this context, “minister” is a

legal term, rather than a religious one, because the ministerial exception prohibits

“government interference with an internal church decision that affects the faith and

mission of the church itself.” Hosanna-Tabor, 565 U.S. at 190. A person does not

have to be “the head of a religious congregation” to qualify for the ministerial

exception, but there is no “rigid formula” for determining when the exception

applies. Id. Instead, we must consider “all the circumstances” of the employment

position at issue. Id.

Here, some of the circumstances weigh in favor of finding the ministerial

exception applies. Seattle’s Union Gospel Mission (SUGM) describes Open Door

Legal Services (ODLS) as a “ministry” that operates with an “evangelical

purpose,” and ODLS staff attorneys “show the love of God by loving the client

holistically, not just attending to legal needs.” Clerk’s Papers (CP) at 371-73.

However, as SUGM has acknowledged, there is “a difference between being

engaged in the ministry of a church and being a minister” for purposes of the