A Michigan court ruled that the "ministerial exception," which bars the civil courts from resolving employment disputes between churches and ministers, applies to whistleblower complaints. A parochial school employed a woman to teach math and religious studies for eight years. After a series of employment-related incidents, none of which involved the subject of religion, the school terminated the teacher's employment. She later sued the church and school (the "defendants") for violating a state law protecting "whistleblowers" from retaliation or other adverse employment actions. The defendants asserted that the teacher was a "minister" for purposes of the ministerial exception, and therefore the court was required by the First Amendment to dismiss the lawsuit.

A state appeals court described the ministerial exception as a "constitutionally compelled exception to the application of employment-discrimination and civil rights statutes to religious institutions and their 'ministerial' employees." It concluded that the teacher was a "minister" for purposes of the ministerial exception, and that the exception applied to whistleblower complaints: "The ministerial exception, as we conceive of it, operates to bar any claim, the resolution of which would limit a religious institution's right to select who will perform particular spiritual functions …. Accordingly, we hold that the ministerial exception may be applied to [whistleblower] claims that involve a religious institution and a ministerial employee."