Obienu v. Archdiocese of New Orleans

All employment discrimination and retaliation claims against the church were barred under the ministerial exception doctrine as a matter of constitutional law.

ReligiousLiberty.TV
February 26, 2026
2 min read
Year: 2025 Court: U.S. District Court
Holding: All employment discrimination and retaliation claims against the church were barred under the ministerial exception doctrine as a matter of constitutional law.

Background

Former Catholic priest Kesiena Dennis Obienu filed a federal lawsuit against the Archdiocese of New Orleans and senior clergy, alleging employment discrimination, retaliation, and unequal treatment during his service as a priest. The specific factual circumstances underlying Obienu's claims are not detailed in available information, but the case centered on his allegations that the Archdiocese violated federal employment laws in their treatment of him as clergy.

Legal Question

Whether federal employment discrimination and retaliation claims brought by a Catholic priest against his archdiocese are barred by the First Amendment's "ministerial exception," which prohibits secular courts from adjudicating certain employment disputes involving religious institutions and their clergy.

Holding

On December 11, 2025, U.S. District Judge Barry Ashe granted summary judgment for the Archdiocese, ruling that all of Obienu's employment-related claims were constitutionally barred under the ministerial exception doctrine. The court held that the First Amendment prevents secular courts from reviewing employment disputes between religious organizations and their ministers, as such judicial intervention would impermissibly entangle the government in religious affairs and undermine religious autonomy.

Significance

This decision reinforces the broad application of the ministerial exception established by the Supreme Court in *Hosanna-Tabor Evangelical Lutheran Church v. EEOC* (2012) and strengthened in *Our Lady of Guadalupe School v. Morrissey-Berru* (2020). The ruling confirms that Catholic priests fall squarely within the ministerial exception's protection, effectively immunizing religious institutions from most employment law claims by clergy members. This continues the trend of courts providing robust protection for religious autonomy in employment decisions, even when discrimination or retaliation is alleged.

Key Statutes & Provisions

  • First Amendment to the U.S. Constitution (Establishment and Free Exercise Clauses)
  • Federal employment discrimination statutes (specific statutes not identified in available information)
  • Ministerial exception doctrine (constitutional doctrine derived from First Amendment principles)
*Note: Specific employment statutes allegedly violated and additional factual details are not provided in available source material.*

Official Documents

Coverage on ReligiousLiberty.TV

📎 Document links found in our articles: 📄 opinion

Obienu v. Archdiocese of New Orleans is a Church & State case decided by the U.S. District Court in 2025. The court held that all employment discrimination and retaliation claims against the church were barred under the ministerial exception doctrine as a matter of constitutional law.

## Background

Former Catholic priest Kesiena Dennis Obienu filed a federal lawsuit against the Archdiocese of New Orleans and senior clergy, alleging employment discrimination, retaliation, and unequal treatment during his service as a priest. The specific factual circumstances underlying Obienu’s claims are not detailed in available information, but the case centered on his allegations that the Archdiocese violated federal employment laws in their treatment of him as clergy.

## Legal Question

Whether federal employment discrimination and retaliation claims brought by a Catholic priest against his archdiocese are barred by the First Amendment’s “ministerial exception,” which prohibits secular courts from adjudicating certain employment disputes involving religious institutions and their clergy.

## Holding

On December 11, 2025, U.S. District Judge Barry Ashe granted summary judgment for the Archdiocese, ruling that all of Obienu’s employment-related claims were constitutionally barred under the ministerial exception doctrine. The court held that the First Amendment prevents secular courts from reviewing employment disputes between religious organizations and their ministers, as such judicial intervention would impermissibly entangle the government in religious affairs and undermine religious autonomy.

## Significance

This decision reinforces the broad application of the ministerial exception established by the Supreme Court in *Hosanna-Tabor Evangelical Lutheran Church v. EEOC* (2012) and strengthened in *Our Lady of Guadalupe School v. Morrissey-Berru* (2020). The ruling confirms that Catholic priests fall squarely within the ministerial exception’s protection, effectively immunizing religious institutions from most employment law claims by clergy members. This continues the trend of courts providing robust protection for religious autonomy in employment decisions, even when discrimination or retaliation is alleged.

## Key Statutes & Provisions

– First Amendment to the U.S. Constitution (Establishment and Free Exercise Clauses)
– Federal employment discrimination statutes (specific statutes not identified in available information)
– Ministerial exception doctrine (constitutional doctrine derived from First Amendment principles)

*Note: Specific employment statutes allegedly violated and additional factual details are not provided in available source material.*