Key Point 8-10.2. Some courts have not recognized the ministerial exception, usually because the complainant was not a minister in either status or function, or was employed by a secular organization. Most of these cases were decided prior to the Supreme Court's ruling in the Hosanna-Tabor case in 2012, and as a result are of dubious value.
A few courts have not applied the ministerial exception, usually because the employee in question was not a "minister."
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