Key Point 8-10.1. The civil courts have consistently ruled that the First Amendment prevents the civil courts from applying employment laws to the relationship between a church and a minister.
A North Carolina federal court ruled that it was barred by the First Amendment guaranty of religious freedom from resolving a minister's claim that his denomination engaged in unlawful racial discrimination in violation of Title VII of the Civil Rights Act of 1964. An African-American minister (the "plaintiff") was employed by a state synod ("regional church") as a missions director. He claimed that he was subjected to racial discrimination and a hostile work environment and that the conditions became so intolerable that he was ultimately forced to resign. He filed a claim of discrimination with the United States Equal Employment Opportunity Commission (EEOC), but the EEOC dismissed this claim on the basis of the so-called "ministerial exception" which prohibits civil courts and agencies from resolving employment disputes between churches and clergy. The plaintiff thereafter sued his denomination in federal court, alleging racial discrimination and hostile work environment under Title VII of the Civil Rights Act of 1964, as well as state law claims for constructive discharge, intentional infliction of emotional distress, and negligent infliction of emotional distress.