Grace MoChridhe was hired as a Media Specialist/Librarian at Academy of Holy Angels, a Catholic school. When she revealed to her employer that she was transgender, she was fired. Ms. MoChridhe brought a lawsuit against Holy Angels and the Archdiocese of St. Paul and Minneapolis, alleging employment discrimination in violation of the Minnesota Human Rights Act, which prohibits discrimination based on sex and sexual orientation. She also brought a tort action for negligence against the Archdiocese.
In defending against the lawsuit, Holy Angels and the Archdiocese have argued that the “ecclesiastical-abstention doctrine” (also known as the “church-autonomy” doctrine) immunizes them from liability. This doctrine limits courts’ ability to intervene in the internal affairs of religious institutions, but it does not give religious institutions free rein to ignore antidiscrimination laws. Still, the trial court held that some of Ms. MoChridhe’s claims were barred by the ecclesiastical-abstention doctrine. Ms. MoChridhe then appealed to the Minnesota Court of Appeals.
On June 4, 2025, Americans United filed an amicus brief in the Minnesota Court of Appeals in support of Ms. MoChridhe. Our brief explains that the ecclesiastical-abstention doctrine does not bar lawsuits in which the claims can be adjudicated by reference to neutral principles of law without interfering with internal church governance or weighing in on doctrinal matters. And because Ms. MoChridhe’s lawsuit can be resolved by answering purely secular questions (such as whether the Archdiocese discriminated on the basis of sex and sexual orientation), the ecclesiastical-abstention doctrine is inapplicable.
