This case arose after Aaron Pulsifer was terminated from his position as Dean of Students and Assistant Principal at Westshore Christian Academy, a private religious school in Muskegon Heights, Michigan. Pulsifer, an African American male, was hired in 2019 and held a leadership role that involved both administrative and spiritual responsibilities. According to the School’s mission, it seeks to “equip students to grow in their relationship with Christ,” and it expected senior staff like Pulsifer to model and lead the School’s Christian values. In addition to student discipline and scheduling duties, Pulsifer led daily staff devotions, prayed over staff, conducted board meeting prayers, and oversaw two religious youth programs—one held after school and another on Sundays. The School described his role to students and staff as that of a “spiritual leader.”
After tensions arose between Pulsifer and the School’s administrator, he alleged that his paycheck was delayed while his white, female coworkers were paid on time, and that these coworkers were treated “better” than him. He also claimed that he raised concerns about the School’s main donor—whom he believed to be a registered sex offender—and was retaliated against for doing so. In August 2022, Pulsifer’s employment was terminated. He filed suit alleging race and sex discrimination in violation of Title VII of the Civil Rights Act of 1964 and Michigan’s Elliott-Larsen Civil Rights Act (“ELCRA”), as well as retaliation for engaging in protected activity under both statutes.
The School moved to dismiss the lawsuit on the grounds that Pulsifer’s role fell within the Ministerial Exception, a First Amendment doctrine that bars employment discrimination claims against religious employers when the plaintiff performs vital religious functions. Because the School attached evidence showing that Pulsifer’s position included religious duties, the trial court converted the motion to one for summary judgment and gave Pulsifer 14 days to respond. Pulsifer did not file any opposing evidence or request additional time to conduct discovery. The trial court found no material disputes and held that the Ministerial Exception applied as a matter of law. Pulsifer appealed.
The Sixth Circuit Court of Appeals affirmed. The Court of Appeals first rejected Pulsifer’s procedural argument, finding that the trial court had properly notified the parties of the conversion to summary judgment and provided a reasonable opportunity to respond. On the merits, the Court emphasized that the Ministerial Exception is grounded in the First and Fourteenth Amendments and protects the right of religious organizations to select and manage employees who play key roles in advancing their religious mission.
Applying the U.S. Supreme Court’s decisions in Hosanna-Tabor Evangelical Lutheran Church & Sch. v. EEOC, 565 U.S. 171 (2012), and Our Lady of Guadalupe Sch. v. Morrissey-Berru, 591 U.S. 171 (2020), the Court held that Pulsifer’s role clearly fell within the scope of the exception. It emphasized that the relevant question is not whether the employee held a clerical title or focused exclusively on religious duties, but whether their functions included key religious leadership or expression. Here, Pulsifer led prayers, guided spiritual formation, directed faith-based student programs, and reinforced the School’s religious purpose in his leadership capacity—all of which the Court concluded placed him squarely within the category of ministerial employees. That his job also included secular administrative responsibilities did not change the outcome. The Court explained that modern doctrine instructs courts to look at “what an employee does,” and not to overemphasize job titles or the proportion of religious to non-religious duties.
Accordingly, the Court of Appeals held that the Ministerial Exception barred Pulsifer’s claims, and it affirmed the judgment dismissing the case in full.
Pulsifer v. Westshore Christian Acad. (6th Cir. 2025) 142 F.4th 859.
Note: This case reinforces that the Ministerial Exception applies to a broad range of school employees, including those whose responsibilities include spiritual formation, prayer leadership, or the advancement of a religious mission.