A federal court in New Orleans has dismissed a lawsuit filed by former Catholic priest Kesiena Dennis Obienu, who alleged employment discrimination, retaliation, and unequal treatment by the Archdiocese of New Orleans and senior clergy. The court ruled that the First Amendment’s “ministerial exception” prohibits secular courts from reviewing employment claims brought by members of the clergy.
On December 11, 2025, U.S. District Judge Barry Ashe granted the Archdiocese’s motion for summary judgment, holding that all of Obienu’s remaining claims were barred as a matter of constitutional law. The decision ends the case in the district court, though Obienu may choose to appeal.
Obienu, a U.S. citizen originally from Nigeria, filed suit in May 2025, alleging he was subject to national origin discrimination and mistreatment during his seminary training and priestly assignments. He claimed that Archdiocesan officials questioned his finances, withheld basic support, and assigned him to unfavorable roles in retaliation for speaking up. He also said he was eventually terminated without notice and later falsely accused of impersonating a chaplain.
The Archdiocese, joined by two priests named as defendants, moved to dismiss the case under the ministerial exception doctrine, citing precedent from Hosanna-Tabor Evangelical Lutheran Church v. EEOC and a recent 2025 Fifth Circuit ruling in McRaney v. North American Mission Board. They argued that Obienu’s claims, although framed under federal employment law, were ecclesiastical in nature and could not be adjudicated without violating the church’s autonomy guaranteed by the First Amendment.
In a 13-page opinion, Judge Ashe agreed. “There can be no doubt,” he wrote, “that the ministerial exception applies here to shield the church’s employment decisions from secular scrutiny or interference.” He noted that Obienu was, at all relevant times, either a priest or preparing for ordination, and that the other individuals involved were also clergy acting within the hierarchical structure of the Church.
The court rejected Obienu’s argument that his claims involved secular workplace discrimination rather than religious doctrine. Citing McRaney, the judge emphasized that even claims arising under generally applicable statutes like Title VII cannot proceed when they challenge the internal management decisions of religious institutions regarding their ministers.
Obienu’s earlier Louisiana state-law claims for defamation and related torts had already been dismissed with prejudice in September due to prescription and failure to state a valid legal claim. The court ruled that it retained jurisdiction over the remaining federal claims and could now dispose of them in full.
The case is captioned Kesiena Dennis Obienu v. Archdiocese of New Orleans, et al., No. 2:25‑cv‑01028 (E.D. La. Dec. 11, 2025). The full decision is available here: DocumentCloud Link.
Obienu has not yet indicated whether he will appeal the ruling to the Fifth Circuit.
TLDR (Too Long / Didn’t Read Summary)
On December 11, 2025, a federal judge dismissed a discrimination lawsuit filed by former priest Kesiena Dennis Obienu against the Archdiocese of New Orleans. Obienu alleged mistreatment and retaliation during his time in seminary and parish ministry. The court ruled that the First Amendment’s ministerial exception bars secular courts from intervening in church employment decisions involving clergy. This decision follows similar rulings applying constitutional protections to internal religious governance. Obienu’s state-law claims were previously dismissed in September. He may appeal, but as of now, the case is closed in district court.
Legal Commentary
This case demonstrates the strict constitutional boundaries courts maintain when it comes to employment disputes involving religious leaders. The ministerial exception, derived from the Religion Clauses of the First Amendment, serves as a shield to protect internal decisions about who may preach, teach, and lead within a religious institution.
The court did not evaluate the factual accuracy of Obienu’s claims. That was not the legal question. Instead, the judge looked solely at whether the law allowed the court to weigh in at all—and concluded that it did not. Once Obienu was identified as a minister under the law, the inquiry ended.
This type of ruling reflects a broad consensus among federal courts, including the U.S. Supreme Court, that secular judges cannot intrude on matters of doctrine, discipline, or internal governance within churches. Whether those decisions appear just or unjust, discriminatory or not, the First Amendment draws a firm line when clergy are involved.
Religious institutions should still proceed with care, as not all employees are covered by the ministerial exception. But this case shows that, for ordained clergy and those in religious training, federal courts will usually decline to review internal employment decisions, even under otherwise valid federal statutes like Title VII.
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AI Disclaimer:
This article was prepared with the assistance of AI. All legal facts and quotations have been verified against official sources. This content is for informational purposes only and does not constitute legal advice. Consult a licensed attorney for legal matters specific to your case.
Tags:
ministerial exception, First Amendment employment law, Title VII clergy lawsuit, Archdiocese of New Orleans, church autonomy doctrine
Case Summary: Obienu v. Archdiocese of New Orleans
Court: U.S. District Court for the Eastern District of Louisiana
Case No.: 2:25‑cv‑01028
Filed: May 22, 2025 PacerMonitor
Document Source (official court filings): https://www.documentcloud.org/documents/26373033‑obienu‑v‑archdiocese‑of‑new‑orleans/ DocumentCloud
What Happened:
Plaintiff Kesiena Dennis Obienu, a U.S. citizen originally from Nigeria, filed a civil lawsuit in May 2025 against the Archdiocese of New Orleans and individual clergy members. Obienu alleged that during his seminary training and service as a priest he suffered:
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wrongful termination,
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discrimination,
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unequal terms and conditions of employment, and
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retaliation. Religion Clause
He also included state‑law claims for defamation, negligence, intentional and negligent infliction of emotional distress, and civil conspiracy. Midpage
Federal Court’s Rulings
1. September 4, 2025 Order:
The federal court granted the Archdiocese’s motion to dismiss Obienu’s Louisiana state‑law claims, holding they were barred by Louisiana’s one‑year prescriptive period (similar to a statute of limitations) and that the complaint failed to state a claim on which relief could be granted. Justia
2. December 11, 2025 Order:
The court granted the Archdiocese’s motion for summary judgment on Obienu’s remaining federal employment and discrimination claims. The court ruled that those claims are barred by the ministerial exception, a constitutional doctrine rooted in the First Amendment that prohibits civil courts from adjudicating employment disputes involving clergy when the dispute touches on church governance. Justia
In other words, because Obienu was training for and serving as a Roman Catholic priest, the court held it could not review his federal Title VII and related employment claims in this lawsuit. Justia
What the “Ministerial Exception” Means Here
The federal ministerial exception is derived from the First Amendment’s protection of religious autonomy and bars courts from hearing claims by “ministers” about internal church employment decisions, even if those claims are styled as discrimination or retaliation. Religion Clause
This doctrine stems from Supreme Court precedent recognizing that civil courts cannot decide employment disputes when doing so would require them to evaluate or second‑guess religious institutions’ decisions about personnel who perform religious roles. DC Employment Law Blog
Outcome of the Case
✔ Obienu’s state‑law claims were dismissed earlier in 2025 on procedural grounds. Justia
✔ Obienu’s federal employment claims were dismissed in December 2025 because the ministerial exception applies. Justia
The court’s December 11, 2025 order ends the case in the district court. Obienu may still appeal this decision to the Fifth Circuit. (Appeal status is not yet reported.)
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