NJ Supreme Court re: terminating a Yeshiva teacher

 

Supreme Court of New Jersey Opinions

Hyman v. Rosenbaum Yeshiva of North Jersey Docket: A-11-23 Opinion Date: July 24, 2024 Areas of Law: Constitutional Law In this case, a Judaic Studies teacher employed by an Orthodox Jewish school was terminated following allegations of inappropriate conduct. The school conducted an investigation and consulted with religious authorities before deciding to terminate the teacher's employment. The school then communicated this decision to the school community, stating that the teacher's conduct was deemed unacceptable and inconsistent with the school's standards. The teacher filed a lawsuit asserting several claims, including defamation. The trial court dismissed all claims, citing the ministerial exception, which bars courts from intervening in employment disputes involving religious institutions and their ministers. The Appellate Division affirmed the dismissal, holding that the ministerial exception applied because the teacher was considered a minister and the defamation claims were related to the school's employment decision. The Supreme Court of New Jersey reviewed the case and reaffirmed the standard set forth in McKelvey v. Pierce, which requires courts to analyze each element of a claim to determine if adjudication would interfere with a religious institution's prerogatives. The Court concluded that adjudicating the defamation claims would require an inquiry into religious law and the school's decision-making process, thus violating the First Amendment. The Court held that the ministerial exception barred the defamation claims and affirmed the Appellate Division's judgment. The Court was equally divided on whether additional discovery was necessary, but ultimately decided that further discovery would not change the constitutional analysis. Therefore, the dismissal of the defamation claims was upheld.