California court rules fired seminary dean's breach of contract claim can proceed

By Asia Mayfield | Oct 9, 2018

SHASTA, Calif. (Legal Newsline) – Part of an appeal filed by a dean of a seminary at a California university over her second termination from the institution has been revived by an appellate court.

On Sept. 25, the 3rd District Court of Appeal of California reversed the summary judgment from the Shasta County Superior Court ruling regarding the plaintiff’s breach of contract claim. Justice Cole Blease determined that the trial court erred when it applied the ministerial exception to all of plaintiff Sarah Sumner’s claims against Simpson University, et al. The rest of the ruling was upheld.  

The ministerial exception is “a ‘nonstatutory, constitutionally compelled’ exception to federal civil rights legislation. ... The idea is that the law should not be construed to govern the relationship of a church and its ministers,'” the ruling states.

The court notes that precedent dictates that ministers can’t sue for employment discrimination when they’re fired. However, questions such as the exception’s effect on breach of contract complaints have not been settled.  

Sumner was employed as the dean of A.W. Tozer Theological Seminary, part of defendant Simpson University’s campus. She was terminated on grounds of insubordination.  

Sumner alleged “breach of contract, defamation, invasion of privacy and intentional infliction of emotional distress,” the ruling states. She claims that the ministerial exception shouldn’t be applied to her case for multiple reasons, including the fact that she doesn’t consider herself to be a minister.  

“Defendants have failed to show that resolution of Sumner’s contract claim would excessively entangle the court in religious matters. However, her tort causes of action are part and parcel of the actions involved in her termination, and are therefore barred by the ministerial exception,” Blease wrote.  

The Appeals Court found that Sumner is indeed a minister. However, that doesn’t satisfactorily solve her breach of contract complaint. Sumner was terminated twice. She was reinstated and terminated again after she sent an email complaining about the University’s management, which violated the protocols she was given when she was reinstated.

Sumner argues that it was impossible for her to be insubordinate because she never received any orders about the emails. 

“This material fact was not resolved by the summary judgment motion. ... Sumner’s breach of contract action is not barred by the ministerial exception. ... Reviewing Sumner’s contract cause of action will not require the court to wade into doctrinal waters because review of the breach of contract claim does not require a review of Sumner’s religious qualification or performance as a religious leader,” the ruling states.

Blease ruled that each party was responsible for their own appeals costs.

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California Third District Court of Appeal Shasta County Superior Court

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