Alcazar v. Corp. of the Catholic Bishop of Seattle, No. 09-35003

Overtime Claim by Minister in Training Under Washington's Minimum Wage Act

In Alcazar v. Corp. of the Catholic Bishop of Seattle, No. 09-35003, an overtime claim brought under Washington's Minimum Wage Act, the court affirmed judgment on the pleadings for defendant where plaintiff was a minister under any reasonable interpretation of the ministerial exception, as he had entered into a church-recognized seminary program to become a minister and brought suit concerning employment decisions arising from work as a seminarian.

As the court wrote:  "Churches, like all other institutions, must adhere to state and federal employment laws. But the federal courts have recognized a "ministerial exception" to that general rule. The exception exempts a church's employment relationship with its "ministers" from the application of some employment statutes, even though the statutes by their literal terms would apply. A key inquiry, therefore, is whether an employee is a "minister" for purposes of the exception."

Related Resources

• Read the Ninth Circuit's Decision in Alcazar v. Corp. of the Catholic Bishop of Seattle, No. 09-35003