Controversy at Catholic school in Georgia over reach of the “ministerial exception

An unusual case arose after the principal of St. Peter Claver School in Savannah, Georgia, elected not to renew the contract of a first-grade teacher, Keshel S. Coates, who finds Catholicism “offensive.” The teacher, described as “an African American woman who is not Catholic”, then sued diocesan and school officials in Coates v. Roman Catholic Diocese of Savannah.

The court rejected two of Coates’ three claims on April 6, 2026, allowing her allegation under the ministerial exception of Title VII of the Civil Rights Act of 1964 to proceed even though she arguably did not serve in such a capacity because she refused to perform religious duties.

In light of the questions Coates raises about the reach of the ministerial exception, this column reviews its background before offering analysis and commentary on its significance for religious freedom.

Background and facts

During her job interview in 2022, the school’s principal, Sister Cheryl Hillig, informed Coates that she would have to accompany her class to Wednesday Masses to monitor their behavior. In response, Coates “stopped the interview to inform [her] that because she was not a Catholic she would not worship as one or accept the job if she had to worship or participate in Catholic doctrine or worship services.”

Even so, Coates accepted the job offer as another teacher provided religious instruction for her first-grade class. Despite her objections to Catholicism, during her two years at the school, Coates signed agreements containing a Statement of Purpose explaining that her job was “expressly conditioned upon the Teacher’s adherence to the doctrines, beliefs and tenets of the Catholic Faith, at all times,” acknowledging that her “position is Ministerial.”

In light of conversations she claimed to have had with the principal, though, Coates thought that these contractual statements only applied to Catholics. Yet, Coates received positive performance reviews and “her non-participation was accepted without discipline or reprimand.”

On May 29, 2024, following an April incident with a teacher, described as “white,” who was charged with assault, Sister Hillig informed her that she would not renew her employment contract because “Ms. Coates did not fully participate in the religious aspects of [the] program as was stated upon hiring that needed to be done.” Consequently, Coates filed pro-se, or “on one’s own behalf,” claims in her ninety-page complaint against the principal and other officials the court described as “confusing.”

Charges

Addressing them in the same order as the court did, it dismissed Coates’ first claim, for religious discrimination under Title VII, an issue different from the ministerial exception.

The court rejected this claim because Title VII exempts any “religious corporation, association, educational institution, or society with respect to the employment of individuals of a particular religion to perform work connected with the carrying on by such corporation, association, educational institution, or society of its activities.”

The court next reviewed Coates’ employment discrimination and retaliation claims based on race under Title VI, following her participation in the investigation of another teacher and the ministerial exception discussed in more detail below. The court was satisfied that despite officials’ formal designation of Coates’ position as ministerial, they did not actually expect her to perform such functions, even accepting her refusal to integrate Catholicism into her work.

Because the principal’s attitude toward Coates apparently changed following her incident with the other teacher, the court found that her complaint plausibly alleged that her job was non-ministerial. Accordingly, the court allowed the ministerial exception and the retaliation claim for “oppos[ing] race discrimination and participat[ing] in a police investigation involving workplace misconduct” to proceed.

Third, the court rejected Coates’ First and Fourteenth Amendment claims premised on Section 1983. The court dismissed these claims because, insofar as Section 1983 applies to state actions and the school where Coates worked is Catholic, they were meritless.

Analysis and observations

As an initial matter, it is confounding why the principal of St. Peter Claver School, Sister Hillig, not only hired non-Catholic Keshel S. Coates, who finds Catholicism “offensive,” but largely excused her from religious duties while later terminating her contract for failing to perform ministerial tasks.

As reflected in the court’s review of the facts, the “he-said-she-said” nature of whether officials expected Coates to comply with St. Peter Claver’s Statement of Purpose is troubling because the court pointed out that she received good evaluations and apparently would have kept her job until the aftermath of the incident involving the other teacher and the criminal investigation.

Turning to the heart of the legal issue involved (rather than examining in detail Title VII, the most far-reaching federal law banning employment discrimination), this analysis highlights its ministerial exception. As noted, this exception applies to religious organizations with respect to the employment of individuals of a particular religion to perform work connected with the carrying on by such corporation, association, educational institution, or society of its activities.

Rooted in the First Amendment Religion Clauses, this exception applies if officials can demonstrate that staff members deemed ministerial employees participate in teaching or other activities integrally related to furthering the spiritual and pastoral missions of their religious institutions. Under this exception, courts defer to the discretion of religious leaders, even if employee contracts do not include the word “minister,” where their jobs involve integrated daily religious functions such as teaching and leading children in prayer.

In 2012, in the first of two cases in which it explicitly used the term “ministerial exception,” the Supreme Court upheld the sole authority of religious leaders to decide to whom it applies. In Hosanna-Tabor Evangelical Lutheran Church and School v. Equal Employment Opportunities Commission, albeit under the Americans with Disabilities Act, not Title VII, the Justices upheld the exception. The Court reasoned that although a teacher in Michigan claimed that her primary duties were secular, the exception precluded her ADA disability-related claim. The Justices emphasized that only church, rather than public, officials can determine who qualifies as ministerial employees.

Eight years later, in 2020, in Our Lady of Guadalupe School v. Morrissey-Berru and St. James School v. Biel, the Supreme Court again upheld the exception, deferring to school officials in specifying who qualified as ministers. The Court rejected the age discrimination and ADA claims of teachers in two Roman Catholic elementary schools in California because, due to their status as ministerial employees, the First Amendment barred their suits.

Because Coats twice signed the Statement of Purpose, under the language of Title VII and Supreme Court precedent, officials of St. Peter Claver School had the legal authority not to renew her employment contract, essentially for breaching her contract. However, the fact that Coates received positive reviews complicates the case. Further, even though the court described Coates’ complaint as “confusing,” and it is unavailable for review, depending on the facts that may emerge should the dispute actually proceed to trial, it remains to be seen whether she may have a valid claim for retaliation based on race, but she is very unlikely to have one under the ministerial exception.

The lesson Coates offers officials in Catholic and other faith-based schools is clear: Be careful in hiring. Put another way, if officials in faith-based schools wish to preserve their religious values, then they should only hire individuals who are clearly committed to their faiths and who do not find shared Christian beliefs “offensive.” It is thus essential for the court to preserve the ministerial exception because it is designed to safeguard the First Amendment and federal statutory rights to religious freedom in employment, regardless of the religions of employees who work in faith-based schools and institutions.

Protecting the ministerial exception is crucial because it affords officials in Catholic and other faith-based schools the right to preserve the religious identities of their institutions by safeguarding their sole authority to hire, retain, and/or dismiss those who are best suited to witness to their values while working to advance institutional missions and goals free from judicial interference.

In light of the significant constitutional and statutory rights at issue under the ministerial exception in Coates, it would be surprising if the court did not rule in favor of the Diocese and St. Peter Claver, thereby securing its right, along with that of other Catholic and faith-based schools, to religious freedom.

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