Combs v. Central Texas (1999)
Supreme Court Decisions on Religious Liberty
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Background Information
Reverend Combs, a graduate of the New Orleans Theological Seminary and ordained Baptist minister, was hired as a United Methodist Singles Minister in 1993 and in 1994, was appointed an an Associate Minister. In 1995, the United Methodist Board of Ordained Ministry unanimously recommended to the Bishop of the Central Texas Conference that she be ordained as a Methodist Minister.
In late 1995, she requested maternity leave which was granted and in early 1996, the Board again unanimously approved of her being ordained. Around this time, she asked why her pay was substantially lower than that of the male ministers she had replaced. She also asked for a housing allowance because she and her family had moved out of the parsonage to make rooom for other church use.
In mid-1996, she took her maternity leave, but needed extra time because of post-partum complications which required surgery, heavy medication and extended rest. At this time her position with her church was challenged by her pastor and immediate supervisor, Dr. John Fielder. He questioned her competence, performance, and honesty and as a result, the church denied her the maternity benefits she had been granted and demanded she repay those what had already been given.
In June of 1996, the Bishop of the Central Texas Conference reappointed Reverend Combs as an Associate Minister for First United. However, when she returned to work on June 17, 1996, she was informed by Dr. Fielder that she had been fired and that she had to leave the church premises. Reverend Combs sought help from the Staff Parish Relations Committee, but was told that Dr. Fielder said she had resigned and that the committee had accepted this resignation. Reverend Combs argued that she had not actually resigned, but they didn't care.
Reverend Combs sued both the Central Texas Conference and First United, alleging discrimination on the basis of her sex and her pregnancy. She argued that the deprivation of her benefits and her termination were the conclusion of a practice of discrimination that included disparate salary and treatment while she was employed. A district court held that the First Amendment prohibits civil review of the decision to terminate her and she appealed to the 5th Circuit Court of Appeals.
Court Decision
The 5th Circuit Court affirmed the lower court ruling and dismissed Reverend Comb's lawsuit. The question before the court was, quite simply, whether the Free Exercise Clause of the First Amendment deprives a federal court of jurisdiction to hear an employment discrimination suit brought against a church by a member of its clergy, even when the church's challenged actions are not based on religious doctrine.
In 1972, the 5th Circuit Court had decided in a case brought against the Salvation Army that religious organizations do not have a blanket exemption for all kinds of discrimination and that discrimination based on race, color, sex, and national origin can be prohibited. However, the government was still prohibited from interfering in ways which placed even in incidental burden on the free exercise of religion:
This case involves the interrelationship between two important governmental directives--the congressional mandate to eliminate discrimination in the workplace and the constitutional mandate to preserve the separation of church and state. As this Court previously observed ...both of these mandates cannot always be followed. In such circumstances, the constitutional mandate must override the mandate that is merely congressional.
Significance
This decision reinforces a distinction drawn in other district court rulings. Citing a D.C. Circuit Court case, the court agreed that government action may burden the free exercise of religion, in violation of the First Amendment, in two quite different ways: first, by interfering with a believer's ability to observe the commands or practices of his faith, and second by intruding on the ability of a church to manage its internal affairs.
According to the courts, other cases, like City of Boerne v. Flores and Employment Division, Oregon v. Smith, addressed the ability of the government to interfere with the ability of a believer to practice his religious faith, but not the ability of a church to manage its own interenal affairs. In particular, the ability of a church to choose and make decisions regarding its ministers has been deemed of utmost importance to the ability of a church to freely function and must, therefore, be given the widest leeway possible.
This ministerial "exception" is not invoked to protect the freedom of an individual to observe a particular command or practice of his church. Instead, it is designed to protect the freedom of a church to select those who will carry out its religious mission. When the state intrudes upon this, it begins making decisions about how a church's religious mission should be advanced, which is impermissible.
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