In a significant decision, a California state appeals court ruled that a Catholic priest who had been discharged from his duties as a chaplain at a Catholic hospital could not sue the hospital for wrongful discharge.
The court observed that "the question of who shall fill the pastoral position is deemed so close to the heart of the religious purpose of the church or congregation as to be entirely an ecclesiastical matter protected from any secular judicial intrusion by the first amendment."
A chaplain at a church-operated hospital is subject to this rule, if his or her duties are primarily religious. Since "government standards have no place in selecting spiritual leaders," the civil courts cannot resolve lawsuits by discharged clergy who claim that their discharge was wrongful.
Presumably, the court added, the same rule might extend to any church employee whose role is primarily religious: "The free exercise of religion includes the right to run large religious institutions—certainly churches, seminaries, and schools, and hospitals, orphanages, and other charitable institutions as well. Such institutions can only be run through employees. It surely also follows that the churches are entitled to insist on undivided loyalty from these employees. The employee accepts responsibility to carry out part of the religious mission …. Churches rely on employees to do the work of the church and to do it in accord with church teaching. When an employee agrees to do the work of the church, he must be held to submit to church authority in much the same way as a member." O'Connor Hospital v. Superior Court, 240 Cal. Rptr. 766 (Cal. App. 6 Dist. 1987)
