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14 Washington opinions name it 2 courts 2006–2026 5 in the last five years
The cases below were cited by Washington courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.
| Case | Followed | Cited |
|---|---|---|
Hosanna-Tabor Evangelical Lutheran Church & School v. Equal Employment Opportunity Commissiongreen2 sentences2026This autonomy includes, under the ministerial exception, “the selection of the 18 No. 87005-0-I/19 individuals who play certain key roles.” Id. 2021In Our Lady of Guadalupe, the Court reviewed and clarified the ministerial exception it previously outlined in Hosanna-Tabor Evangelical Lutheran Church & Sch. v. Equal Emp’t Opportunity Comm’n, 565 U.S. 171 , 132 S. Ct. 694 , 181 L. | 2 | 3 |
cluster 19566green2 sentences2007Conference of Seventh-Day Adventists, 772 F.2d 1164 , 1168 (4th Cir. 1985))); Starkman v. Evans, 198 F.3d 173, 175 (5th Cir. 1999) (holding that a choir director qualified as a “minister” for purposes of the ministerial exception because she “perform [ed] ministerial functions that warrant the First Amendment’s protections against undue interference with the personnel decisions of churches and religious leaders”); Equal Employment Opportunity Comm’n v. Catholic Univ. of Am., 317 U.S. App. D.C. 343 , 83 F.3d 455, 463 (1996) (“[T]he ministerial exception encompasses all employees of a religious 2007See Alicea-Hernandez v. Catholic Bishop of Chi., 320 F.3d 698, 703 (7th Cir.2003) ("In determining whether an employee is considered a minister for the purposes of applying [the ministerial] exception, we do not look to ordination but instead to the function of the position."); Equal Employment Opportunity Comm'n v. Roman Catholic Diocese of Raleigh, N.C., 213 F.3d 795, 801 (4th Cir.2000) ("Our inquiry . . . focuses on `the function of the position' at issue and not on categorical notions of who is or is not a `minister.'"); Starkman v. Evans, 198 F.3d 173, 175 (5th Cir.1999) (holding that a c | 2 | 2 |
Equal Employment Opportunity Commission and Elizabeth McDonough v. The Catholic University of Americagreen2 sentences2007Conference of Seventh-Day Adventists, 772 F.2d 1164 , 1168 (4th Cir. 1985))); Starkman v. Evans, 198 F.3d 173, 175 (5th Cir. 1999) (holding that a choir director qualified as a “minister” for purposes of the ministerial exception because she “perform [ed] ministerial functions that warrant the First Amendment’s protections against undue interference with the personnel decisions of churches and religious leaders”); Equal Employment Opportunity Comm’n v. Catholic Univ. of Am., 317 U.S. App. D.C. 343 , 83 F.3d 455, 463 (1996) (“[T]he ministerial exception encompasses all employees of a religious 2007Conference of Seventh-Day Adventists, 772 F.2d 1164 , 1168 (4th Cir. 1985))); Starkman v. Evans, 198 F.3d 173, 175 (5th Cir. 1999) (holding that a choir director qualified as a “minister” for purposes of the ministerial exception because she “perform [ed] ministerial functions that warrant the First Amendment’s protections against undue interference with the personnel decisions of churches and religious leaders”); Equal Employment Opportunity Comm’n v. Catholic Univ. of Am., 317 U.S. App. D.C. 343 , 83 F.3d 455, 463 (1996) (“[T]he ministerial exception encompasses all employees of a religious | 2 | 2 |
Millicent P. Hollins v. Methodist Healthcare, Inc., Doing Business as Methodist University Hospitalgreen2 sentences2007App. 456, 462 , 9 P.3d 845 (2000). ¶10 The ministerial exception “precludes subject matter jurisdiction over claims involving the employment relationship between a religious institution and its ministerial employees.” Hollins v. Methodist Healthcare, Inc., 474 F.3d 223, 225 (6th Cir. 2007) (citing Serbian E. 2007In re Estate of Peterson, 102 Wash.App. 456, 462 , 9 P.3d 845 (2000). ¶ 10 The ministerial exception "precludes subject matter jurisdiction over claims involving the employment relationship between a religious institution and its ministerial employees." Hollins v. Methodist Healthcare, Inc., 474 F.3d 223, 225 (6th Cir.2007) (citing generally Serbian E. | 2 | 2 |
Dike v. Dikegreen2 sentences2006See Marley v. Dep’t of Labor & Indus., 125 Wn.2d 533, 543 , 886 P.2d 189 (1994) (“ ‘[T]he power to decide includes the power to decide wrong, and an erroneous decision is as binding as one that is correct until set aside or corrected in a manner provided by law.’ ” (quoting Dike v. Dike, 75 Wn.2d 1, 8 , 448 P.2d 490 (1968))); State v. Adams, 91 Wn.2d 86, 91 , 586 P.2d 1168 (1978) (“ ‘A defendant is not entitled to perfect counsel, to error-free representation.... 2006See Marley v. Dep’t of Labor & Indus., 125 Wn.2d 533, 543 , 886 P.2d 189 (1994) (“ ‘[T]he power to decide includes the power to decide wrong, and an erroneous decision is as binding as one that is correct until set aside or corrected in a manner provided by law.’ ” (quoting Dike v. Dike, 75 Wn.2d 1, 8 , 448 P.2d 490 (1968))); State v. Adams, 91 Wn.2d 86, 91 , 586 P.2d 1168 (1978) (“ ‘A defendant is not entitled to perfect counsel, to error-free representation.... | 2 | 2 |
Marley v. Department of Labor & Industriesgreen2 sentences2006See Marley v. Dep’t of Labor & Indus., 125 Wn.2d 533, 543 , 886 P.2d 189 (1994) (“ ‘[T]he power to decide includes the power to decide wrong, and an erroneous decision is as binding as one that is correct until set aside or corrected in a manner provided by law.’ ” (quoting Dike v. Dike, 75 Wn.2d 1, 8 , 448 P.2d 490 (1968))); State v. Adams, 91 Wn.2d 86, 91 , 586 P.2d 1168 (1978) (“ ‘A defendant is not entitled to perfect counsel, to error-free representation.... 2006See Marley v. Dep’t of Labor & Indus., 125 Wn.2d 533, 543 , 886 P.2d 189 (1994) (“ ‘[T]he power to decide includes the power to decide wrong, and an erroneous decision is as binding as one that is correct until set aside or corrected in a manner provided by law.’ ” (quoting Dike v. Dike, 75 Wn.2d 1, 8 , 448 P.2d 490 (1968))); State v. Adams, 91 Wn.2d 86, 91 , 586 P.2d 1168 (1978) (“ ‘A defendant is not entitled to perfect counsel, to error-free representation.... | 2 | 2 |
Our Lady of Guadalupe School v. Morrissey-Berrugreen2 sentences2026This meant in turn that the exemption applied coextensively with, and its availability would be determined by, the scope of the Mission’s implicated religious freedoms, in that case the ministerial exception. 8 Under the ministerial exception, “to preserve a church’s independent authority” on matters of faith and doctrine, courts must abstain from adjudicating “employment disputes involving those holding certain important positions with churches and other religious institutions.” Our Lady of Guadalupe Sch. v. Morrissey-Berru, 591 U.S. 732 , 746-47, 140 S. Ct. 2049 , 207 L. 2026This meant in turn that the exemption applied coextensively with, and its availability would be determined by, the scope of the Mission’s implicated religious freedoms, in that case the ministerial exception. 8 Under the ministerial exception, “to preserve a church’s independent authority” on matters of faith and doctrine, courts must abstain from adjudicating “employment disputes involving those holding certain important positions with churches and other religious institutions.” Our Lady of Guadalupe Sch. v. Morrissey-Berru, 591 U.S. 732 , 746-47, 140 S. Ct. 2049 , 207 L. | 1 | 2 |
State v. Adamsgreen2 sentences2006See Marley v. Dep’t of Labor & Indus., 125 Wn.2d 533, 543 , 886 P.2d 189 (1994) (“ ‘[T]he power to decide includes the power to decide wrong, and an erroneous decision is as binding as one that is correct until set aside or corrected in a manner provided by law.’ ” (quoting Dike v. Dike, 75 Wn.2d 1, 8 , 448 P.2d 490 (1968))); State v. Adams, 91 Wn.2d 86, 91 , 586 P.2d 1168 (1978) (“ ‘A defendant is not entitled to perfect counsel, to error-free representation.... 2006See Marley v. Dep’t of Labor & Indus., 125 Wn.2d 533, 543 , 886 P.2d 189 (1994) (“ ‘[T]he power to decide includes the power to decide wrong, and an erroneous decision is as binding as one that is correct until set aside or corrected in a manner provided by law.’ ” (quoting Dike v. Dike, 75 Wn.2d 1, 8 , 448 P.2d 490 (1968))); State v. Adams, 91 Wn.2d 86, 91 , 586 P.2d 1168 (1978) (“ ‘A defendant is not entitled to perfect counsel, to error-free representation.... | 1 | 2 |
Erdman v. Chapel Hill Presbyterian Churchgreen2 sentences2021See, e.g., Erdman v. Chapel Hill Presbyterian Church, 175 Wn.2d 659, 665-66 , 286 P.3d 357 (2012) -21- Woods v. Seattle’s Union Gospel Mission, 96132-8 (Stephens, J., dissenting in part and concurring in part) (plurality opinion) (remanding Title VII of the Civil Rights Act of 1964 claim for further proceedings to establish whether the ministerial exception applies). 2021See, e.g., Erdman v. Chapel Hill Presbyterian Church, 175 Wn.2d 659, 665-66 , 286 P.3d 357 (2012) -21- Woods v. Seattle’s Union Gospel Mission, 96132-8 (Stephens, J., dissenting in part and concurring in part) (plurality opinion) (remanding Title VII of the Civil Rights Act of 1964 claim for further proceedings to establish whether the ministerial exception applies). | 1 | 1 |
Mrs. Billie B. McCLURE, Plaintiff-Appellant, v. the SALVATION ARMY, Defendant-Appelleegreen1 sentence2021See McClure v. Salvation Army, 460 F.2d 553, 558 (5th Cir. 1972). | 1 | 1 |
State v. Toneygreen1 sentence2019Toney, 149 Wn. | 1 | 1 |
Alcazar v. Corporation of the Catholic Archbishopgreen1 sentence2010In Alcazar v. Corp. of the Catholic Archbishop, 598 F.3d 668, 676 (9th Cir.2010), the Ninth Circuit sets forth a three-part test for determining whether the exception applies. [8] Neither the record before the trial court nor before us adequately demonstrates that Erdman's claims would fail under the ministerial exception. | 1 | 1 |
Equal Employment Opportunity Commission v. The Roman Catholic Diocese of Raleigh, North Carolina Sacred Heart Cathedralgreen1 sentence2007See Alicea-Hernandez v. Catholic Bishop of Chi., 320 F.3d 698, 703 (7th Cir.2003) ("In determining whether an employee is considered a minister for the purposes of applying [the ministerial] exception, we do not look to ordination but instead to the function of the position."); Equal Employment Opportunity Comm'n v. Roman Catholic Diocese of Raleigh, N.C., 213 F.3d 795, 801 (4th Cir.2000) ("Our inquiry . . . focuses on `the function of the position' at issue and not on categorical notions of who is or is not a `minister.'"); Starkman v. Evans, 198 F.3d 173, 175 (5th Cir.1999) (holding that a c | 1 | 1 |
Gloria Alicea-Hernandez v. The Catholic Bishop of Chicago, a Corporation Solegreen1 sentence2007See Alicea-Hernandez v. Catholic Bishop of Chi., 320 F.3d 698, 703 (7th Cir.2003) ("In determining whether an employee is considered a minister for the purposes of applying [the ministerial] exception, we do not look to ordination but instead to the function of the position."); Equal Employment Opportunity Comm'n v. Roman Catholic Diocese of Raleigh, N.C., 213 F.3d 795, 801 (4th Cir.2000) ("Our inquiry . . . focuses on `the function of the position' at issue and not on categorical notions of who is or is not a `minister.'"); Starkman v. Evans, 198 F.3d 173, 175 (5th Cir.1999) (holding that a c | 1 | 1 |
| Case | Negative | Cited |
|---|---|---|
| No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway. | ||
| Case | Cited | Years |
|---|---|---|
Elvig v. Ackles
green
2 sentences2010They further argued that the WLAD exempts religious organizations from its prohibitions. ¶ 17 After hearing argument, the trial court stated that it lacked sufficient facts to decide whether Erdman was a minister and declined to rule in the defendant's favor on the ministerial exception. [8] It further dismissed Erdman's intentional infliction of emotional distress (outrage) claims because she failed to meet the relevant legal standards. ¶ 18 Relying on the Division One decision in Elvig v. Ackles, 123 Wash.App. 491 , 98 P.3d 524 (2004), the trial court also addressed the viability of certain 2010They further argued that the WLAD exempts religious organizations from its prohibitions. ¶17 After hearing argument, the trial court stated that it lacked sufficient facts to decide whether Erdman was a minister and declined to rule in the defendant’s favor on the ministerial exception. 7 It further dismissed Erdman’s intentional infliction of emotional distress (outrage) claims because she failed to meet the relevant legal standards. ¶18 Relying on the Division One decision in Elvig v. Ackles, 123 Wn. | 4 | 2007–2010 |
In Re The Dependency Of: J.d.p. And J.d.p.
neutral
2 sentences2026App.2d 744, 759, 487 P.3d 960 (2021). 2026App.2d 744, 759, 487 P.3d 960 (2021). | 3 | 2022–2026 |
Elvig v. Ackles
green
2 sentences2010They further argued that the WLAD exempts religious organizations from its prohibitions. ¶ 17 After hearing argument, the trial court stated that it lacked sufficient facts to decide whether Erdman was a minister and declined to rule in the defendant's favor on the ministerial exception. [8] It further dismissed Erdman's intentional infliction of emotional distress (outrage) claims because she failed to meet the relevant legal standards. ¶ 18 Relying on the Division One decision in Elvig v. Ackles, 123 Wash.App. 491 , 98 P.3d 524 (2004), the trial court also addressed the viability of certain 2010App. 491 , 98 P.3d 524 (2004), the trial court also addressed the viability of certain claims under the ecclesiastical abstention doctrine. 8 It dismissed all claims that were based on facts that had been set forth in Erdman’s Form No. 26 grievance. | 3 | 2007–2010 |
Serbian Eastern Orthodox Diocese for United States and Canada v. Milivojevich
green
2 sentences2007Orthodox Diocese, 426 U.S. 696 ). ¶11 Division One of this court has recognized the ministerial exception. 2007Orthodox Diocese, 426 U.S. 696 , 96 S.Ct. 2372 , 49 L.Ed.2d 151 ). ¶ 11 Division One of this court has recognized the ministerial exception. | 2 | 2007–2007 |
In Re Estate of Peterson
green
2 sentences2007App. 456, 462 , 9 P.3d 845 (2000). ¶10 The ministerial exception “precludes subject matter jurisdiction over claims involving the employment relationship between a religious institution and its ministerial employees.” Hollins v. Methodist Healthcare, Inc., 474 F.3d 223, 225 (6th Cir. 2007) (citing Serbian E. 2007In re Estate of Peterson, 102 Wash.App. 456, 462 , 9 P.3d 845 (2000). ¶ 10 The ministerial exception "precludes subject matter jurisdiction over claims involving the employment relationship between a religious institution and its ministerial employees." Hollins v. Methodist Healthcare, Inc., 474 F.3d 223, 225 (6th Cir.2007) (citing generally Serbian E. | 2 | 2007–2007 |
Bryce v. Episcopal Church In The Diocese Of Colorado
green
2 sentences2007Conference of Seventh-Day Adventists, 772 F.2d 1164 , 1168 (4th Cir. 1985))); Starkman v. Evans, 198 F.3d 173, 175 (5th Cir. 1999) (holding that a choir director qualified as a “minister” for purposes of the ministerial exception because she “perform [ed] ministerial functions that warrant the First Amendment’s protections against undue interference with the personnel decisions of churches and religious leaders”); Equal Employment Opportunity Comm’n v. Catholic Univ. of Am., 317 U.S. App. D.C. 343 , 83 F.3d 455, 463 (1996) (“[T]he ministerial exception encompasses all employees of a religious 2007D.C. 343, 83 F.3d 455, 463 (D.C.Cir. 1996) ("[T]he ministerial exception encompasses all employees of a religious institution, whether ordained or not, whose primary functions serve its spiritual and pastoral mission."); cf. Bryce v. Episcopal Church in the Diocese of Colo., 289 F.3d 648 , 658 n. 2 (10th Cir.2002) (observing that "[c]onsideration of the ministerial exception would require us to determine whether Bryce . . . was a `minister' for purposes of [the ministerial] exception," where Bryce was not ordained as a minister). | 2 | 2007–2007 |
Erdman v. Chapel Hill Presbyterian Church
neutral
1 sentence2012Erdman v. Chapel Hill Presbyterian Church, 156 Wn. | 1 | 2012–2012 |
State v. Rooks
neutral
1 sentence2009State v. Rooks, 130 Wash.App. 787, 797-801 , 125 P.3d 192 (2005), review denied, 158 Wash.2d 1007 , 143 P.3d 830 (2006). | 1 | 2009–2009 |
CURLEY ELEC., INC. v. Bills
neutral
1 sentence2009State v. Rooks, 130 Wash.App. 787, 797-801 , 125 P.3d 192 (2005), review denied, 158 Wash.2d 1007 , 143 P.3d 830 (2006). | 1 | 2009–2009 |
State v. Rooks
green
1 sentence2009State v. Rooks, 130 Wash.App. 787, 797-801 , 125 P.3d 192 (2005), review denied, 158 Wash.2d 1007 , 143 P.3d 830 (2006). | 1 | 2009–2009 |
Rayburn v. General Conference Of Seventh-Day Adventists
green
1 sentence2007Conference of Seventh-Day Adventists, 772 F.2d 1164 , 1168 (4th Cir. 1985))); Starkman v. Evans, 198 F.3d 173, 175 (5th Cir. 1999) (holding that a choir director qualified as a “minister” for purposes of the ministerial exception because she “perform [ed] ministerial functions that warrant the First Amendment’s protections against undue interference with the personnel decisions of churches and religious leaders”); Equal Employment Opportunity Comm’n v. Catholic Univ. of Am., 317 U.S. App. D.C. 343 , 83 F.3d 455, 463 (1996) (“[T]he ministerial exception encompasses all employees of a religious | 1 | 2007–2007 |
Ianicelli v. Peterson
neutral
1 sentence2007In re Estate of Peterson, 102 Wash.App. 456, 462 , 9 P.3d 845 (2000). ¶ 10 The ministerial exception "precludes subject matter jurisdiction over claims involving the employment relationship between a religious institution and its ministerial employees." Hollins v. Methodist Healthcare, Inc., 474 F.3d 223, 225 (6th Cir.2007) (citing generally Serbian E. | 1 | 2007–2007 |
Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.
Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.