The court noted that "the Supreme Court has expressed no view on whether the ministerial exception bars claims other than employment discrimination claims," and it noted that a prior federal appeals court ruling had concluded that the exception "did not bar a breach of contract claim when resolution of such a claim is subject to entirely neutral methods of proof." Minker v. Baltimore Annual Conference of United Methodist Church, 894 F.2d 1354 (D.C. Cir. 1990).
The pastor claimed that the regional church discriminated against him on the basis of age because its officer forced him to retire from his position as pastor by telling him that he needed "to retire" because there were "younger people" to take his place. The court noted that the pastor had abandoned this claim on appeal, but even if he had not done so, the ministerial exception would have barred the claim:
His allegation is that the officer "forced him to retire because of his age," thereby ending his tenure as pastor. The age discrimination claim before the court thus "is an employment discrimination [claim] brought on behalf of a minister, challenging his church's decision to fire him." The ministerial exception bars such a claim. That bar is in place because the court's involvement in assessing the propriety of a pastor's termination would improperly entangle it in "an internal church decision that affects the faith and mission of the church itself."
Breach of contract to pay a stipend
The pastor claimed that the regional church's discontinuation of his monthly $1,500 stipend amounted to a breach of contract. The court noted that in the District of Columbia, the elements of a breach of contract claim are: "(1) a valid contract between the parties; (2) an obligation or duty arising out of the contract; (3) a breach of that duty; and (4) damages caused by breach."