Atkins

INTRODUCTION

Appellant Frances Atkins was a long-term employee of respondent St. Cecilia Catholic School. In her final year of employment, Atkins worked part-time as an art teacher and office administrator. Following her discharge, Atkins filed this action against St. Cecilia for age discrimination in violation of the California Fair Employment and Housing Act (FEHA; Gov. Code, § 12900 et seq.) The trial court granted St. Cecilia’s motion for summary judgment on the ground that Atkins’s suit was barred by the ministerial exception, a constitutional doctrine that precludes certain employment claims brought against a religious institution by its ministers. We conclude there are triable issues of material fact as to whether the ministerial exception applies in this case. We therefore reverse the judgment in favor of St. Cecilia and remand for further proceedings consistent with this opinion.

FACTUAL AND PROCEDURAL BACKGROUND

I. St. Cecilia’s philosophy and mission

St. Cecilia is a Catholic elementary school within the Archdiocese of Los Angeles (ADLA). The mission of the ADLA “encompasses the belief of continuing the redemptive work of Jesus Christ, living and proclaiming the…