Biel v. St. James School, 2018 WL 6597221 (9th Cir. 2018)

Kristen Biel was fired from her fifth grade teaching position at St. James Catholic School after she told the school that she had breast cancer and would need to miss work to undergo chemotherapy. Following her termination, Biel alleged that the school had violated the Americans with Disabilities Act (“ADA”). The district court dismissed Biel’s lawsuit on the ground that it was barred by the First Amendment’s “ministerial exception” to generally applicable employment laws such as the ADA. The Ninth Circuit reversed, holding that under the totality of the circumstances test, the ministerial exception did not bar Biel’s claims because she did not qualify as a minister of the Catholic Church.