The regional church argued that the ministerial exception barred this claim, but the court disagreed. The court quoted from the Minker case (see above): "A church is always free to burden its activities voluntarily through contracts, and such contracts are fully enforceable in civil court." In Minker, the court considered a breach of an oral employment contract claim asserted by a minister. The court recognized that "it could turn out that in attempting to prove his case, the minister will be forced to inquire into matters of ecclesiastical policy even as to his contract claim," which would require a dismissal of this claim.
The same analysis is warranted here, the DC court concluded:
If it turns out that resolution of the pastor's claim that the regional church breached a contract to pay him a stipend requires excessive entanglement with religious doctrine, the court can grant summary judgment in favor of the regional church. But because at this early stage it is not entirely clear that resolution of [the pastor's breach of contract claim] will require anything other than "neutral methods of proof," dismissal on ministerial exception grounds is not warranted.