Keshel Coates, a first-grade teacher at St. Peter Claver Catholic School, a private Catholic school in Macon, Georgia, filed suit after the School declined to renew her contract at the end of the 2023-2024 school year. Coates, an African American woman who is not Catholic and described Catholicism as “offensive,” alleged that the non-renewal was based on race and religion and brought claims under Title VII, Section 1981, and Section 1983.
During her initial interview in 2022, Coates told the School’s principal that she would not accept the position if it required her to participate in Catholic worship or doctrine. The principal reassured her that she would not be responsible for teaching religion and would only need to escort students to weekly Mass to supervise behavior. Coates accepted the position and, over the next two school years, taught secular subjects such as reading, science, and social studies. Another teacher provided religious instruction, and Coates did not lead prayer or participate in Catholic worship activities.
Despite these assurances, each year Coates signed employment agreements stating that her position was “ministerial” and required her to adhere to Catholic doctrine and serve as a faith-based role model. The School also evaluated teachers on their ability to incorporate Catholic values into instruction. Coates alleged that she believed these provisions applied only to Catholic teachers, particularly because her non-participation in religious activities was accepted without discipline and she received positive performance evaluations during her employment.
The situation changed in April 2024, when Coates provided a statement to police regarding an incident involving another teacher and a student, about which Coates informed the student’s parents. Following that report, Coates alleged that school leadership questioned her actions, accused her of harboring ill will toward the other teacher, and began documenting minor performance issues such as tardiness. Coates further alleged that the other teacher, who was white, was not disciplined.
On May 29, 2024, the School informed Coates that her contract would not be renewed. The stated reason was that she had not fully participated in the religious aspects of the program, as required by her role.
The School moved to dismiss Coates’ complaint, relying primarily on two legal arguments: that it was permitted to make religious-based employment decisions under Title VII’s religious exemption, and that the First Amendment’s ministerial exception barred Coates’ claims entirely.
The Court first addressed Coates’ religious discrimination claims under Title VII. Title VII generally prohibits discrimination based on religion, but it expressly permits religious institutions to employ individuals whose beliefs align with the institution’s faith for work connected to its activities. Because Coates alleged that the School declined to renew her contract due to her lack of participation in Catholic practices, the Court held that these claims fell within the statutory exemption and dismissed them.
The Court then turned to the ministerial exception, which is a constitutional doctrine that bars certain employment discrimination claims involving employees who perform religious functions. The Court emphasized that the analysis for the ministerial exception depends on the employee’s actual duties rather than contractual labels alone.
Although Coates’ contract described her role as ministerial and required her to model the Catholic faith, the Court found that she plausibly alleged that her day-to-day responsibilities were primarily secular. She did not teach religion, did not lead students in prayer, and did not participate in religious services beyond supervising students. The Court also noted her allegation that the School knowingly permitted her to perform the role in this manner for two years. Based on these facts, the Court concluded that it was plausible that Coates did not perform a ministerial function and therefore declined to dismiss her race discrimination and retaliation claims at this stage.
Finally, the Court dismissed Coates’ constitutional claims under Section 1983, which require action by a state actor. The Court found that the Catholic school, as a private institution, was not a state actor, even though it may have received federal funding.
Accordingly, the Court dismissed Coates’ religious discrimination and constitutional claims but allowed her race discrimination and retaliation claims to proceed.
Coates v. Roman Cath. Diocese (M.D.Ga. Apr. 6, 2026) 2026 WL 926130.
Note: This case highlights the importance of carefully evaluating roles at religious schools that include both secular and religious functions. While religious institutions retain discretion to make faith-based employment decisions, courts will look beyond contractual labels and examine the employee’s actual duties when applying the ministerial exception.