Jimmy Kirby v. Lexington Theological Seminary

Summary

The Kentucky Supreme Court adopted the ministerial exception as an affirmative defense in employment disputes involving religious institutions and held that Kirby, a seminary professor who taught Christian social ethics and performed significant religious functions, was a ministerial employee. The exception barred his race-discrimination claim but did not bar his contract claims because enforcing the Seminary's alleged tenure agreement would not interfere with minister selection or require resolution of religious doctrine. The court therefore reversed summary judgment and remanded for proceedings on whether a contract existed and was breached.