Reyzl Grace MoChridhe worked as the media specialist and librarian at the Academy of Holy Angels, a private Catholic high school in Minnesota affiliated with the Archdiocese of St. Paul and Minneapolis. During her first year in the role, her duties were entirely secular: overseeing the library program, teaching research skills, and supporting the School’s academic mission. Holy Angels’ job posting and employment agreement did not reference religious training or ministerial responsibilities, though the School’s bylaws stated that the Board must act in accordance with Catholic teaching as defined by the Archdiocese.
In spring 2022, before staff were required to indicate their intent to return for the following school year, MoChridhe met with the principal to confirm she was welcome back. The principal expressed that the School wished to renew her contract, and MoChridhe then shared that she is a transgender woman beginning her transition. According to the complaint, the principal replied that the Archdiocese would not support her transition and that she could not continue in her role if she intended to live publicly as a woman.
About a week later, the principal met with her again and introduced the “Guiding Principles for Catholic Schools and Religious Education Concerning Human Sexuality and Sexual Identity,” a document issued by the Archdiocese outlining Catholic doctrine regarding sex, gender, and identity. The Guiding Principles direct Catholic schools to treat sex as determined at birth, require that names, pronouns, and single-sex activities align with biological sex, and prohibit expressions of identity that conflict with Catholic teaching. Holy Angels had not previously shared the Guiding Principles with her. The principal asked whether MoChridhe could comply with them, and after reviewing the document, she said she could not. According to the complaint, the principal told her that the Guiding Principles were the only reason she would not be offered a renewed contract and asked her to submit a resignation letter.
Before the renewal deadline, MoChridhe contacted the School’s HR department to state that she wished to return and would sign a contract if permitted, emphasizing that the Guiding Principles were the sole barrier. In June 2022, Holy Angels posted the media specialist position again using the same secular job description, later informing her that the position had been filled.
MoChridhe filed a charge of discrimination with the Minnesota Department of Human Rights and then brought suit alleging discrimination based on sex and sexual orientation under the Minnesota Human Rights Act (MHRA), aiding and abetting discrimination by the Archdiocese, and negligence. The Archdiocese moved to dismiss, arguing that adjudicating the claims would violate the First Amendment’s church autonomy doctrine because the nonrenewal decision rested entirely on religious doctrine governing employees in Catholic schools. The trial court granted the motion, and MoChridhe appealed.
The Minnesota Court of Appeals affirmed the dismissal, concluding that the complaint itself made clear that Holy Angels’ decision not to renew MoChridhe’s contract rested entirely on the religious directives set forth in the Guiding Principles. While the MHRA generally prohibits employment discrimination, the Court explained that the First Amendment bars courts from intruding into internal church decisions that touch on matters of faith, doctrine, or mission. Because Holy Angels is a Catholic school whose bylaws require adherence to Catholic teaching, and because the Guiding Principles set out doctrinal expectations for all staff, the Court determined that adjudicating the claims would necessarily require it to evaluate, second-guess, or override the Archdiocese’s application of those teachings. That type of judicial involvement, the Court held, would impermissibly entangle the state in religious governance and interfere with the church’s constitutional autonomy to direct its schools.
On appeal, MoChridhe noted that the Archdiocese did not raise the ministerial exception at the trial court level and effectively argued that the ministerial exception was the only way a religious employer could obtain First Amendment religious protections against an employment-discrimination claim. The Court clarified that the ministerial exception was not the basis for its decision and that the trial court did not consider the ministerial exception either. Instead, the Court of Appeal emphasized that the broader church autonomy doctrine independently foreclosed her claims: even for non-ministerial employees, courts cannot require a religious institution to retain an employee who cannot abide by faith-based directives central to its mission. Because enforcing the MHRA under these circumstances would interfere with a core religious decision, the First Amendment required dismissal.
Accordingly, the Court of Appeals affirmed dismissal of all claims.
MoChridhe v. Acad. of Holy Angels (Ct.App. Dec. 1, 2025, No. A25-0559) 2025 LX 594111.
Note: This decision highlights the potential broad reach of the church autonomy doctrine, which protects religious schools from judicial interference in employment decisions that are grounded in religious doctrine, even when the employee holds a secular position.