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MARY CHRISTINE O'CONNOR, Plaintiff-Appellant, v. CHURCH OF ST. IGNATIUS LOYOLA, ET AL., Defendants-Respondents.

The court properly determined that it lacked subject matter jurisdiction over these causes of action. Plaintiff was a pastoral associate and chaplain whose primary function served the spiritual and pastoral mission of the church. Interference with this mission would violate the Free Exercise Clause of the First Amendment, under the "ministerial exception" to employment discrimination claims ( Equal Empl. Opportunity Commn. v. Catholic Univ. of Am., 83 F.3d 455 [DC Cir]; Rayburn v. General Conference of Seventh-Day Adventists, 772 F.2d 1164 [4th Cir], cert denied 478 U.S. 1020; Kraft v. Grace Church, 2004 US Dist LEXIS 4234 [SD NY]). Accordingly, we need not reach plaintiff's remaining contentions.

THIS CONSTITUTES THE DECISION AND ORDER OF THE SUPREME COURT, APPELLATE DIVISION, FIRST DEPARTMENT.

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O'CONNOR v. CHURCH OF ST. IGNATIUS LOYOLA
(Jun 17, 2004)