Wash. Supreme Court published opinion — 961328.pdf

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Commissioned.’” Id. at 191. The receipt of such title “reflected a significant degree of

religious training followed by a formal process of commissioning.” Id. The teacher had

to complete eight college-level courses in subjects such as biblical interpretation and

church doctrine, obtain the endorsement of her local church, and pass an oral examination

by a faculty committee at a Lutheran college. Id. She was then commissioned as a

minister only upon election by the congregation and such status could be rescinded only

upon a supermajority vote of the congregation. Id. Further, she claimed a special

housing allowance on her taxes available only to employees earning their compensation

in the exercise of the ministry. Id. at 192.

As for the teacher’s job duties, she was charged with nurturing the Christian

development of the students at her Lutheran school. In addition to secular subjects, she

taught religion classes four days a week, led her students in prayer three times a day, took

her students to weekly chapel services, and conducted such services herself twice a year.

She also led her fourth graders in daily morning devotionals. Id. In short, the teacher

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No. 96132-8

“performed an important role in transmitting the Lutheran faith to the next generation.”

Id.

The Court made clear in Our Lady of Guadalupe that the above circumstances

were important to consider, but not “essential” to qualifying as a minister. 140 S. Ct. at

2062-63. “What matters, at bottom, is what an employee does.” Id. at 2064. To that

end, the Court concluded the Catholic school teachers at issue performed vital religious