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Ministerial Exception Applied To Dismiss Prof's Racial Discrimination Claims

By Howard M. Friedman

In Adams v. Indiana Wesleyan University, 2010 U.S. Dist. LEXIS 71403 (ND Ind., July 15, 2010), an Indiana federal district court applied the ministerial exception to dismiss a Title VII racial discrimination claim filed against a religiously-sponsored university by a former faculty member. Janice B. Adams, an African-American, was employed by Indiana Wesleyan University for 17 years as a Professor and Chair of the Social Work Department. The University describes itself on its website as "an evangelical Christian comprehensive university that is committed to liberal arts and professional education." Adams, who often clashed with her supervisor, claims she was subjected to severe and pervasive racial discrimination that led to her resignation. In dismissing her claim, the court said:

[W]hile Adams may very well have been free to present and discuss secular topics and issues in her classroom, it is also true that she was charged with incorporating the doctrine of the Wesleyan Church into her curriculum.... The fact that she claims she was forced to resign as a result of pervasive racial harassment as opposed to any sort of doctrinal or theological dispute does not take this case outside the parameters of the ministerial exception.

Full post as published by Religion Clause on July 18, 2010 (boomark / email).