Sander v. Westchester Reform Temple

Summary

The Court of Appeals affirmed dismissal of Sander's wrongful-termination claim, holding that the ministerial exception barred application of Labor Law § 201-d to her employment relationship with the Temple. The Court concluded that the offer letter conclusively established that her core teaching duties were religious in nature, while expressly declining to decide whether blogging or the public expression of views qualifies as protected recreational activity. Judge Rivera concurred in the result but would have affirmed on the statutory material-conflict-of-interest exception instead.