Peter Chapla served as the principal of Father Judge High School, a Roman Catholic school, from June 2018 to June 2022. The School is operated by the Office of Catholic Education and the Archdiocese of Philadelphia and is explicitly focused on developing young adults through Catholic value-based education.
Chapla applied for the principal position in 2018 and was required to submit a letter from his pastor confirming his active participation in a Roman Catholic parish. Chapla obtained the letter and later accepted the position. Upon being hired, he was formally inducted during a Mass where he pledged to administer the School with the authority of the Office of Catholic Education and the Oblates of St. Francis de Sales.
As principal, Chapla had major responsibility for the School’s religious education program. His duties included:
Despite his role in the School’s religious mission, Chapla alleged that his termination in June 2022 was abrupt and motivated by age and health-related discrimination. He then filed suit under multiple employment discrimination statutes, including the Americans with Disabilities Act (ADA), the Family and Medical Leave Act (FMLA), the Age Discrimination in Employment Act (ADEA), the Pennsylvania Human Relations Act (PHRA), and the Philadelphia Fair Practices Ordinance (PFPO).
The School, the Archdiocese, and the Office of Catholic Education (Defendants) moved for summary judgment, arguing that the Ministerial Exception barred Chapla’s claims. The Ministerial Exception is a legal doctrine rooted in the First Amendment, which prevents courts from interfering in employment disputes involving religious leaders or key employees responsible for conveying religious doctrine.
The ministerial exception applies to employees with significant religious responsibilities, even if they do not hold an official ministerial title. Courts consider multiple factors in determining whether an employee is a “minister,” including the employee’s title and job description, participation in religious rituals, religious teaching responsibilities, and the employer’s expectations of the employee’s religious role.
Applying this framework, the Court found ample evidence that Chapla’s position was religious in nature, emphasizing: his formal induction during Mass, where he pledged to uphold Catholic values; his direct oversight of religious education, campus ministry, and theology faculty; his active participation in school Masses, retreats, and religious programming; and his role in integrating Salesian virtues into the School’s curriculum.
Chapla argued that his job was primarily administrative, but the Court rejected this distinction, holding that the ministerial exception is not negated by the presence of administrative duties, and that what matters most is whether the employee played a key role in conveying the religious mission of the institution. Here, the Court found that Chapla was responsible for living the mission day in and day out, serving as a “pastor” of the School, and overseeing the Catholic culture of the School. The Court also reasoned that an employee who supervises spiritual functionaries performs spiritual functions themselves, as Chapla did in overseeing the theology teachers.
The Court ruled that Chapla’s role as principal was ministerial in nature, making him subject to the ministerial exception. Because the First Amendment prohibits courts from interfering in religious employment decisions, Chapla’s claims under the ADA, FMLA, ADEA, PHRA, and PFPO were barred as a matter of law. The Court granted summary judgment in favor of the School and dismissed the case.
Chapla v. Father Judge High Sch. (E.D.Pa. Jan. 29, 2025) 2025 U.S.Dist.LEXIS 15417.
Note: This case reinforces that the ministerial exception extends beyond ordained clergy and can apply to lay employees with significant religious responsibilities.