Labor & Employment Law Daily Wrap Up, COVERAGE, LIABILITY—E.D. La.: Ministerial exception barred discrimination claims brought by priest who alleged involuntary ordainment, (Dec 12, 2025)

By Marjorie Johnson, J.D.

All the allegedly unlawful incidents arose while he was either training or working under the auspices of the archdiocese, “either as a seminarian or as an ordained priest.”

A priest of Nigerian origin who claimed he was subjected to unlawful discrimination and retaliation both while he was in training to become a priest and after being ordained, failed to defeat summary judgment on his Title VII claims against the Archdiocese of New Orleans because they were barred by the church autonomy doctrine and its ministerial exception. “This is not a case where a peripheral church employee may or may not be categorized as a ‘minister’ depending on whether he or she was a teacher of the faith,” observed a federal district court in Louisiana. Rather, the plaintiff, “as a Roman Catholic priest or priest-in-training, was a minister charged with leading a religious organization in the various ways assigned and serving as a messenger of its faith” (Obienu v. Archdiocese of New Orleans, No. 25-1028 (E.D. La. Dec. 11, 2025)).

Priest-in-training. The plaintiff, a U.S. citizen of Nigerian origin, moved to New Orleans in 2017 to pursue a Master of Arts degree in theological studies at the Notre Dame Seminary to prepare for the priesthood. He allegedly began experiencing national origin discrimination in 2019, when the archdiocese’s director of vocations (a priest) questioned his source of a downpayment for a used car, demeaned him, and summoned him to face a disciplinary panel.

Ordained. He further claimed that the archbishop refused his request to leave the archdiocese. As a result, he was ordained as a priest “against his express wishes.”

Church assignment. In July 2022, he was assigned to a church where he allegedly experienced more discrimination by the senior priest there. He claimed that after he complained, he was subjected to a retaliatory investigation and removed from the parish.

Terminated, assigned to nursing home. In January 2023, the archbishop assigned him to work at two nursing homes, which forced him to live in a senior-living apartment without a food allowance. He later learned that the assignment resulted from his termination in August 2023, when he was reassigned to a different church and discovered that his 401(k) retirement account had been terminated.

Disciplinary investigation. In April 2024, he received a letter advising him that he was under investigation for impersonating a chaplain, which he claimed was retaliatory. He then took a leave of absence and filed this lawsuit against the archdiocese, the director, and the senior priest.

Motion for summary judgment. The defendants argued that summary judgment was warranted since the ministerial exception of the church autonomy doctrine bars secular courts from adjudicating a ministers’ claims of employment discrimination against religious organizations. In particular, they claimed the priest’s employment discrimination claims were barred because they arose out of a “disgruntled former minister’s dissatisfaction with how [the archdiocese] managed his role as a minister within its system of religious governance.”

Fifth Circuit’s McRaney decision. The district court began by observing that, just two months ago, the Fifth Circuit in McRaney v. North American Mission Board of the Southern Baptist Convention, Inc., outlined the First Amendment’s church autonomy doctrine. Quoting Supreme Court precedent, the McRaney court observed that “[t]he First Amendment’s Religion Clause enshrines that principle within the church autonomy doctrine, which shields religious institutions from interference by state and federal courts.” To that end, “[t]he ‘general principle of church autonomy’ guarantees to religious institutions ‘independence in matters of faith and doctrine and in closely linked matters of internal government.’”

The Supreme Court has further stated that the ministerial exception, which is a “component” of the church autonomy doctrine, mandates that courts “stay out of employment disputes involving those holding certain important positions within churches and other religious institutions.” The exception applies to persons holding the title of “minister” and also to other employees who lead a religious organization, conduct worship services or important religious ceremonies or rituals, or serve as a messenger or teacher of its faith. With this backdrop, the McRaney court specifically stated that “[t]he ministerial exception bars the application of even neutral, generally applicable employment discrimination statutes—such as … Title VII.”

Ministerial exception bars claims. Accordingly, summary judgment was warranted given “the Fifth Circuit’s broad pronouncement in McRaney—based on a thorough historical and legal analysis—that the ministerial exception bars secular courts from considering Title VII and related state-law employment claims brought by a minister against a religious organization.” Significantly, it was undisputed that, at all relevant times, the plaintiff was either a Roman Catholic priest, or he was training to be one. Moreover, all the incidents he alleged constituted unlawful employment discrimination arose while he was either training or working under the auspices of the archdiocese “either as a seminarian or as an ordained priest.”

Further, the persons he accused of acting unlawfully were themselves ordained priests or the archbishop. “This is not a case where a peripheral church employee may or may not be categorized as a ‘minister’ depending on whether he or she was a teacher of the faith,” observed the court. Rather, the plaintiff “was a minister charged with leading a religious organization in the various ways assigned and serving as a messenger of its faith.”

The case is No. 25-1028.

Judge: Ashe, B.

Attorneys: Pius Akamdi Obioha (Law Offices of Pius Obioha & Associates) for Kesiena Dennis Obienu.

Companies: Archdiocese of New Orleans

Cases: CoverageLiability NationalOrigin Discrimination Retaliation LouisianaNews