Alcazar

Churches, like all other institutions, must adhere to state and federal employment laws. But the federal courts have recognized a “ministerial exception” to that general rule. The exception exempts a church’s employment relationship with its “ministers” from the application of some employment statutes, even though the statutes by their literal terms would apply. A key inquiry, therefore, is whether an employee is a “minister” for purposes of the exception. Where, as here, the plaintiff alleges that he “entered the seminary to become a Catholic priest” and performed his duties “in a ministerial placement,” “[a]s part of [his] preparation for ordination into the priesthood,” we hold that he is a “minister” for purposes of the ministerial exception.

Plaintiff Cesar Rosas appeals from the district court’s grant of judgment on the pleadings to Defendants Corporation of the Catholic Archbishop of Seattle and Father Horatio Yanez on Rosas’ overtime claim brought under Washington’s Minimum Wage Act and from the court’s subsequent decision denying him leave to amend the complaint to add a minimum wage claim. In Rosas v. Corporation of Catholic Archbishop of Seattle, 598 F.3d 668…