Court Affirms Minister-Clergy Exception to Title VII
On February 1, 2007, the Fifth Circuit Court of Appeals, in Boggan v. Miss. Conference of the United Methodist Church, No. 06-60782 (5th Cir. 2007), affirmed a ruling by the Southern District of Mississippi dismissing a Title VII race discrimination claim under the doctrine of the minister-clergy exception. The Plaintiff, a former minister, had filed a suit alleging race discrimination against the Mississippi Conference of the United Methodist Church. The lower Court dismissed the claim as being barred by the minister-clergy exception to Title VII. The Fifth Circuit agreed and stated that this exception is "firmly rooted" in the Free Exercise clause of the First Amendment of the United States Constitution and has been recognized in at least two other past Fifth Circuit opinions. The Court went on to note that they would continue to recognize the exception to Title VII's ban on discrimination unless the United States Supreme Court ruled otherwise.
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