Reyzl Grace MoChridhe v. Academy of Holy Angels, Archdiocese of St. Paul and Minneapolis, ...

STATE OF MINNESOTA
IN COURT OF APPEALS
A25-0559

Reyzl Grace MoChridhe,
Appellant,

vs.

Academy of Holy Angels,
Respondent,

Archdiocese of St. Paul and Minneapolis,
Respondent.

Filed December 1, 2025
Affirmed
Larkin, Judge

Hennepin County District Court
File No. 27-CV-24-11601

Jess Braverman, Brittany Stewart (pro hac vice), Gender Justice, St. Paul, Minnesota; and

Joni M. Thome, Katherine Rollins, Wanta Thome PLC, Minneapolis, Minnesota (for
appellant)

Katie M. Connolly, Sara Gross Methner, Sara L. Lewenstein, Nilan Johnson Lewis PA,
Minneapolis, Minnesota; and

Thomas B. Wieser, Thomas Wieser Law, West St. Paul, Minnesota (for respondent Holy
Angels)

Paul J. Zech, Scott D. Blake, Felhaber Larson, Minneapolis, Minnesota; and

Lorie S. Gildea, Greenberg Traurig, LLP, Minneapolis, Minnesota (for respondent
Archdiocese)

Leslie L. Lienemann, Celeste E. Culberth, Culberth & Lienemann, LLP, St. Paul,
Minnesota; and

Brian T. Rochel, Kitzer Rochel, PLLP, Minneapolis, Minnesota; and
Claire Bruner-Wiltse, Schaefer Halleen, LLC, Minneapolis, Minnesota; and

Drew Kudlinski, HKM Employment Attorneys, LLP, Minneapolis, Minnesota; and

Stephen M. Premo, Premo Frank PLLC, Minneapolis, Minnesota; and

Zane Umsted, Madia Law LLC, Minneapolis, Minnesota (for amicus curiae Employee
Lawyers of the Upper Midwest and Minnesota National Employment Lawyers
Association)

Caitlin L. Opperman, Nichols Kaster, PLLP, Minneapolis, Minnesota; and

Teresa Nelson, Alicia Granse, Hannah Grayson, American Civil Liberties Union of
Minnesota, Minneapolis, Minnesota (for amicus curiae American Civil Liberties Union of
Minnesota)

Celeste E. Culberth, Culberth & Lienemann, LLP, St. Paul, Minnesota (for amicus curiae
Americans United for Separation of Church and State)

Considered and decided by Bond, Presiding Judge; Ross, Judge; and Larkin, Judge.

SYLLABUS

A court properly dismisses sex or sexual orientation employment-discrimination

claims against a church under Minn. R. Civ. P. 12.02(e) if the allegations in the complaint,

construed in plaintiff’s favor, establish that the court’s adjudication of plaintiff’s claims

would violate the religious freedom provisions of the First Amendment as a matter of law.

OPINION

LARKIN, Judge

Appellant, a former media specialist/librarian at a Catholic school, challenges the

district court’s dismissal of her employment-discrimination claims against respondent

Archdiocese, which were based on sex and sexual orientation. Because appellant’s

2
complaint establishes—as a matter of law—that appellant’s claims are foreclosed by the

First Amendment church autonomy doctrine, we affirm.

FACTS

In August 2024, appellant Reyzl Grace MoChridhe sued respondents Academy of

Holy Angels and Archdiocese of St. Paul and Minneapolis,1 alleging discrimination,

specifically, nonrenewal of MoChridhe’s employment contract based on MoChridhe’s sex

and sexual orientation. Our recitation of the facts is taken from MoChridhe’s complaint

and the documents referenced in her complaint. We accept the factual allegations in her

complaint as true and construe all reasonable inferences in her favor. See Bodah v.

Lakeville Motor Express, Inc., 663 N.W.2d 550, 553 (Minn. 2003) (“The reviewing court

must consider only the facts alleged in the complaint, accepting those facts as true and must

construe all reasonable inferences in favor of the nonmoving party.”).

As alleged in her complaint, MoChridhe is Jewish and “a transgender woman,

meaning she was assigned male at birth but lives and identifies as a woman.” On July19,

2021, Holy Angels presented MoChridhe “with an offer of employment and a detailed job

description for a Media Specialist/Librarian position to be reviewed and signed.”

MoChridhe “signed the Employment Agreement that same day.” According to

MoChridhe’s complaint, the job description contains a “Purpose” section that “describes

the mission statement of [Holy Angels]” and states “[t]he mission of [Holy Angels] is to

educate and nurture a diverse student population” and “[t]he Media Specialist/Librarian

1
According to the complaint, Holy Angels is registered as a nonprofit corporation and the
Archdiocese is a Minnesota diocesan corporation.

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selects media resources, serves patrons and collaborates with the professional staff to

support the mission of the Academy of Holy Angels.” According to the job description,

“[t]he Library/Media Specialist administers the library department and promotes library

literacy. Library literacy encompasses all the skills needed to locate, retrieve, evaluate,

and use information.” The job posting for the media specialist/librarian position was based

entirely on secular criteria. Holy Angels did not expect MoChridhe to evangelize the

Catholic faith or to lead students in prayer.

According to the complaint, “[t]he ‘Bylaws of [Holy Angels]’ state that [Holy

Angels’] Board’s actions are to be at all times ‘informed by and conducted in accordance

with the tenets of the Roman Catholic Church as determined by the Archbishop of the

Archdiocese.’” Holy Angels provided MoChridhe with an employee handbook, which

indicated that her benefits would be provided by the Archdiocese.

MoChridhe’s employment agreement covered the 2021-22 school year. In March

2022, all Holy Angels staff were asked to submit an intention to renew their employment

agreement for the 2022-23 school year by April 22, 2022. If they did not do so, their

resignations would be assumed. Soon after, MoChridhe met with Holy Angels’ principal.

MoChridhe told the principal that she wanted to come back but that she first wanted to

confirm there was interest in having her return. The principal assured MoChridhe that the

school wanted her to return. MoChridhe then “revealed she had come out as transgender

and was starting the process of transitioning to live as her female self.” The principal said

the Archdiocese would not support MoChridhe’s transition, and it would not be possible

for MoChridhe to continue working at the school if she was determined to transition.

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 About a week later, MoChridhe again met with the principal and was presented with

a copy of the “Guiding Principles for Catholic Schools and Religious Education

Concerning Human Sexuality and Sexual Identity.” Because of their relevance to the

issues in this case, we repeat them in their entirety.

Guiding Principles for Catholic Schools and Religious
Education Concerning Human Sexuality and Sexual Identity

Purpose

The Catholic school is committed to providing a safe
environment that allows students to flourish academically,
physically, and spiritually. Catholic schools are obliged to
provide an education and resources consistent with Catholic
teaching. The starting point for Catholic education is a deeply
held understanding that affirms the God-given irrevocable
dignity of every human person.

Catholic teaching permeates and shapes the ethos of
Catholic schools. Informed by Catholic teaching, these
Guiding Principles shall inform the creation of policies,
handbooks, statements, employee agreements, training for
employees, and the approach to accompaniment in the Catholic
schools of the Diocese of [insert], thus ensuring that the
immeasurable dignity of every child is protected and respected,
particularly as it relates to foundational beliefs of the Catholic
Church:

• God created each person body and soul “in His own
image, in the image of God he created them; male and
female he created them” (Gen. 1:27). The dignity of
each person and the source of his or her most important
identity is found in this creation in the image and
likeness of God (CCC §364).

• God uses the body to reveal to each person his or her
sexual identity as male or female. A person’s embrace
of his or her God-given sexual identity is an essential

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 part of living a fulfilled relationship with God, with
oneself, and with each other (Laudato Si §155).

• The harmonious integration of a person’s sexual identity
with his or her sex is an expression of the inner unity
and reality of the human person made body and soul in
the image and likeness of God (CCC §364-65).

• The physical, moral, and spiritual differences between
men and women are equal and complementary. The
flourishing of family life and society depend in part on
how this complementarity and equality are lived out
(CCC §2333-34).

• All students and families deserve interactions with
Catholic school communities that are marked by
respect, charity, and the truth about human dignity and
God’s love (Deus Caritas Est §20).

Application of Guiding Principles

The aforementioned Guiding Principles are practically
applied in Catholic schools. Catholic schools in the Diocese of
[insert] will relate to each student in a way that is respectful of
and consistent with each student’s God-given sexual identity
and biological sex. To this end, below are some examples of
how these Guiding Principles apply to organizations that teach
children and youth in the name of the Catholic Church in the
Diocese of [insert].

1. All school policies, procedures, resources, employee
training, and assistance given to families will be consistent
with the Church’s teaching on the dignity of the human person,
including human sexuality. Reflective of a commitment to a
culture of transparency and understanding, these policies will
be made available in writing to members of the school
community by way of inclusion in relevant handbooks,
agreements, and statements.

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2. Student’s name and pronoun usage will correspond to his/her
sex (see definitions).

3. Student access to facilities and overnight accommodations
will align with his/her sex.

4. Eligibility for single-sex curricular and extracurricular
activities will be based on the sex of the child.

5. Expressions of a student’s sexual identity are prohibited
when they cause disruption or confusion regarding the
Church’s teaching on human sexuality.

6. Students who attend and employees who work at a Catholic
school can expect that the school acknowledges that God has
created each person as a unity of body and soul, as male or
female, and that God-designed sexual expression and behavior
must be exclusively oriented to love and life in marriage
between one man and one woman.

7. Schools will communicate with parents or guardians about
their child’s behavior at school and inform them of any
concerns relating to the physical, emotional, social, and
spiritual health, safety, or welfare of their child, except when
advised otherwise by law enforcement or a social service
agency.

Definitions

1. Sex refers to a person’s biological identification as male or
female based upon physical characteristics present at birth.

2. Sexual identity refers to a person’s identity as male or female
that is congruent with one’s sex.

3. Sexual binary refers to the God-given gift of the human
family created male or female in the image and likeness of
God.

4. Transgender or gender non-conforming is an adjective
describing a person who perceives his or her sexual identity to
be different from his or her sex and publicly presents himself
or herself as the opposite sex or outside the sexual binary. Such

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 public expressions that are intended to communicate a sexual
identity different from one’s sex include, but are not limited to,
utilizing pronouns of the opposite sex, changing one’s name to
reflect the cultural norms of the opposite sex, wearing a
uniform designated for the opposite sex, and undergoing
surgery to change the appearance of one’s reproductive or
sexual anatomy.

The principal asked MoChridhe if she could adhere to the Guiding Principles. Holy

Angels had not previously shown MoChridhe the Guiding Principles or anything like it.

After reviewing the Guiding Principles, MoChridhe said that “she did not believe she could

abide by the directives.” MoChridhe’s complaint alleges that the Guiding Principles

“instruct schools who teach in the name of the Catholic Church to discriminate against

transgender and gender-nonconforming students by, for example, refusing to recognize

their pronouns and preferred name if they are inconsistent with a student’s sex assigned at

birth, and refusing to allow LGBTQ+ students to express their sexual identity.”

According to MoChridhe’s complaint, the principal told MoChridhe “that the

Guiding Principles document was the only reason she was not being offered a renewed

contract.” It was clear to MoChridhe that “what she was being told was that she would not

be allowed to work at [Holy Angles] given that she is transgender.” The principal asked

MoChridhe to submit a formal resignation letter by June 7, 2022. MoChridhe did not do

so.

On April 22, 2022, the final day to submit an employee’s intent to return,

MoChridhe contacted Holy Angels’ human resources (HR) department. The HR

representative was not aware of MoChridhe’s previous conversations with the principal.

MoChridhe told the HR representative that “she wanted it on record that she wanted to

8
return for the following school year, that she would sign a contract if allowed, and that the

Guiding Principles document was the only reason she cannot return.”

In June 2022, Holy Angels posted a job opening for the library/media specialist

position. MoChridhe’s complaint states that “[a]s with the previous posting for the

position, the posting did not list any ministerial duties and did not require any religious

training or education.” MoChridhe applied for the position using the same application that

had been used the year prior with updated information including the experience she gained

during her year of employment at Holy Angels. MoChridhe did not get a response to the

updated application until August 1, 2022, when an HR representative sent her a letter

thanking her for the application but indicating the position had been filled. MoChridhe

finished out her 2021-22 contract with Holy Angels on August 15, 2022.

MoChridhe filed a discrimination charge with the Minnesota Department of Human

Rights (MDHR). MoChridhe submitted her charge on a form, and she checked boxes

indicating employment discrimination based on sex and sexual orientation/gender identity

in violation of the Minnesota Human Rights Act (MHRA), Minn. Stat. §§ 363A.001-.50

(2022). In the form, MoChridhe described the basis for her discrimination claims and

discussed the Guiding Principles and the Archdiocese’s involvement. Later, MoChridhe

notified the MDHR of her intent to bring a civil action.

MoChridhe’s ensuing complaint against Holy Angels and the Archdiocese raised

three MHRA claims and one common-law claim: (1) discrimination in employment based

on sexual orientation (gender identity) under Minn. Stat. § 363A.08, subd. 2,

(2) discrimination in employment based on sex under Minn. Stat. § 363A.08, subd. 2,

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(3) aiding and abetting discrimination by the Archdiocese under Minn. Stat. § 363A.14,

and (4) discrimination-based negligence by the Archdiocese.

The Archdiocese moved to dismiss MoChridhe’s claims against the Archdiocese

under Minn. R. Civ. P. 12.02(e), for failure to state a claim upon which relief can be

granted. The district court granted that motion and dismissed MoChridhe’s claims against

the Archdiocese with prejudice.

The district court relied on two documents referenced in the complaint and filed by

the Archdiocese in support of its motion to dismiss: the Guiding Principles and a copy of

the discrimination charge that MoChridhe filed with the MDHR. The district court

concluded that MoChridhe’s claims against the Archdiocese were based on the Guiding

Principles, which the Archdiocese imposed on Holy Angels, and that resolution of

MoChridhe’s claims therefore required examination of the Archdiocese’s faith-based

doctrines, the relationship between the Archdiocese and Holy Angels, church governance,

and the provision of education through Holy Angels. Again, MoChridhe’s complaint

alleges that Holy Angels’ bylaws state that Holy Angels’ board’s actions are to be at all

times “informed by and conducted in accordance with the tenets of the Roman Catholic

Church as determined by the Archbishop of the Archdiocese.” The district court therefore

determined that the religious-freedom provisions in the United States and Minnesota

Constitutions precluded MoChridhe’s claims. The district court also determined that

MoChridhe’s MHRA sexual-orientation claim failed under Minn. Stat. § 363A.26, an

MHRA religious-association exemption. The district court rejected the Archdiocese’s

other proffered grounds for dismissal.

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 Final partial judgment was entered, and this appeal followed.

ISSUE

Did the district court err in dismissing MoChridhe’s claims against the Archdiocese
on the ground that the claims are precluded by the church autonomy doctrine under
the First Amendment to the United States Constitution?

ANALYSIS

We review a grant of a motion to dismiss under Minn. R. Civ. P. 12.02(e) for failure

to state a claim de novo, and we must “determine whether the pleadings set forth a legally

sufficient claim for relief.” Abel v. Abbott Nw. Hosp., 947 N.W.2d 58, 68 (Minn. 2020).

We consider only the facts alleged in the complaint, accepting those facts as true and

construing all reasonable inferences in favor of the nonmoving party. Bodah, 663 N.W.2d

at 553. We may consider documents referenced in the complaint. N. States Power Co. v.

Minn. Metro. Council, 684 N.W.2d 485, 490 (Minn. 2004). And we are not bound by legal

conclusions in a complaint. Ward v. El Rancho Manana, Inc., 945 N.W.2d 439, 445 (Minn.

App. 2020), rev. denied (Minn. Sept. 29, 2020). A claim survives a motion to dismiss for

failure to state a claim “if it is possible on any evidence which might be produced,

consistent with the pleader’s theory, to grant the relief demanded.” Walsh v. U.S. Bank,

N.A., 851 N.W.2d 598, 603 (Minn. 2014). Constitutional issues are questions of law that

we review de novo. Pfeil v. St. Matthews Evangelical Lutheran Church, 877 N.W.2d 528,

536 (Minn. 2016).

Under the MHRA, it is an unfair employment practice for an employer to refuse to

hire or to discharge an employee because of the employee’s sex or sexual orientation.

Minn. Stat. § 363A.08, subd. 2. And, under the version of the MHRA in effect at the time

11
of the events underlying MoChridhe’s claims, sexual orientation was defined to include

“having or being perceived as having a self-image or identity not traditionally associated

with one’s biological maleness or femaleness.” Minn. Stat. § 363A.03, subd. 44. This was

generally understood to extend the protections of the MHRA to transgender individuals.

See Cooper v. USA Powerlifting, __ N.W.3d ___, ___, 2025 WL 2970023, at *7 (Minn.

Oct. 22, 2025) (noting the parties’ agreement “that discrimination based on transgender

status is discrimination based on sexual orientation under the 2018 version of the

MHRA”).2 It is also unlawful for any person “intentionally to aid, abet, incite, compel, or

coerce a person to engage in any of the practices forbidden by” the MHRA. Minn. Stat.

§ 363A.14(1).

There is no dispute that MoChridhe sufficiently pleaded her claims for violations of

the MHRA. Instead, we are asked to decide whether those MHRA claims, as pleaded, are

foreclosed by the First Amendment.

The First Amendment

The First Amendment to the United States Constitution provides that “Congress

shall make no law respecting an establishment of religion, or prohibiting the free exercise

thereof.” U.S. Const. amend. I. The religious freedom provisions in the First Amendment

“protect the right of churches and other religious institutions to decide matters of faith and

doctrine without government intrusion.” Our Lady of Guadalupe Sch. v. Morrissey-Berru,

2
In 2023, the legislature changed the definition for sexual orientation and added a
definition for gender identity. 2023 Minn. Laws ch. 52, art 19, §§ 46-48, at 1150. The
legislature also changed the employment-discrimination statute to address gender identity.
2023 Minn. Laws ch. 52, art 19, §§ 52-56, at 1152-55.

12
591 U.S. 732, 746 (2020) (quotations omitted). “State interference in that sphere would

obviously violate the free exercise of religion.” Id. Although religious institutions are not

generally immune from secular laws, the First Amendment protects their “autonomy with

respect to internal management decisions that are essential to the institution’s central

mission.” Id. “[A]ny attempt by government to dictate or even to influence [matters of

faith and doctrine] would constitute one of the central attributes of an establishment of

religion,” and “[t]he First Amendment outlaws such intrusion.” Id.

The Church Autonomy Doctrine

“The legal principle that has come to be known as the ‘ecclesiastical abstention

doctrine’ or the ‘church autonomy doctrine’ has its roots in a line of U.S. Supreme Court

decisions regarding church property and church schisms.”3 Pfeil, 877 N.W.2d at 532.

Although none of those decisions directly addresses the factual circumstances of this case,

“several helpful rules can be drawn from them.” Id. at 534. Among them is the following

rule: although courts can resolve disputes involving religious organizations, they may do

so “only if” (1) they are “able to resolve the matter by relying exclusively on neutral

principles of law,” (2) they do not “disturb the ruling of a governing ecclesiastical body

with respect to issues of doctrine,” and (3) “the adjudication does not interfere with an

internal church decision that affects the faith and mission of the church itself.” Id.

(quotation omitted). The third factor is dispositive here.

3
We use the phrase “church autonomy doctrine” in this opinion.

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 In Doe v. Lutheran High School, this court concluded that the First Amendment

prohibited resolution of a discrimination claim brought under the MHRA by an ordained

minister who was a religious teacher and campus pastor at a religious high school, and who

claimed that he was wrongfully discharged based on his sexual orientation. 702 N.W.2d

322, 324 (Minn. App. 2005), rev. denied (Minn. Oct. 26, 2005). We reasoned that “Doe’s

assertion that he should not have been discharged based on his sexual orientation would

require the court to analyze and apply church doctrine to assess his argument” and that

“this type of searching inquiry intrudes into church doctrine and church administrative

matters and engenders a prohibited relationship between the church and the judiciary.” Id.

at 327.

We reach a similar conclusion here. We recognize that the allegations in

MoChridhe’s complaint are unlike the facts in Doe in that she is not an ordained minister,

she was not a teacher or pastor at the school, and her position was secular. Regardless of

the secular nature of the job posting, MoChridhe’s complaint alleged that “[t]he ‘Bylaws

of [Holy Angels]’ state that [Holy Angels’] Board’s actions are to be at all times ‘informed

by and conducted in accordance with the tenets of the Roman Catholic Church as

determined by the Archbishop of the Archdiocese.’” Thus, consideration of MoChridhe’s

claims—as alleged in her complaint—would require the judiciary to consider the role that

church doctrine played in the decision not to renew her employment contract with Holy

Angels. Importantly, it would require the judiciary to consider the Archdiocese’s decision

to require an employee in one of its Catholic schools to adhere to its faith-based Guiding

Principles in the school setting.

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 As set forth above, the Guiding Principles document includes a “Purpose” section

that sets forth the “foundational beliefs of the Catholic Church.” It also addresses

application of the Guiding Principles stating that Catholic schools in the Diocese “will

relate to each student in a way that is respectful of and consistent with each student’s God-

given sexual identity and biological sex.” The Guiding Principles document defines “sex”

as “a person’s biological identification as male or female based upon physical

characteristics present at birth” and defines “sexual identity” as “a person’s identity as male

or female that is congruent with one’s sex.” Finally, the Guiding Principles document

directs, among other things, that “[s]tudent’s name and pronoun usage will correspond to

his/her sex,” “[s]tudent access to facilities and overnight accommodations will align with

his/her sex,” “[e]ligibility for single-sex curricular and extracurricular activities will be

based on the sex of the child,” and “[e]xpressions of a student’s sexual identity are

prohibited when they cause disruption or confusion regarding the Church’s teaching on

human sexuality.”

According to MoChridhe’s complaint, Holy Angels’ principal asked MoChridhe if

she “could adhere to the document’s requirements.” “After reviewing the Guiding

Principles,” MoChridhe said “she did not believe she could abide by the directives.” As to

the directives, MoChridhe’s complaint alleges that the Guiding Principles document

“instruct[s] schools who teach in the name of the Catholic Church to discriminate against

transgender and gender-nonconforming students by, for example refusing to recognize

their pronouns and preferred name if they are inconsistent with a student’s sex assigned at

birth, and refusing to allow LGBTQ+ student to express their sexual identity.” In sum,

15
MoChridhe’s complaint alleges that the directives implementing the Guiding Principles in

the school setting were discriminatory and she informed Holy Angels that she could not

abide by them.

MoChridhe argues that adjudication of her claims will not require the judiciary to

interpret church doctrine. She may be correct, but that does not end our inquiry under the

church autonomy doctrine. The Archdiocese’s decision to require an employee in one of

its Catholic schools to adhere to its faith-based Guiding Principles in the school setting

“affects the faith and mission of the church itself.” Pfeil, 877 N.W.2d at 534 (quotation

omitted). As to this issue, courts have recognized that “[t]he education of children within

a Catholic school system is a significant factor in the propagation of the Catholic faith.”

Hill-Murray Fed’n of Tchrs. v. Hill-Murray High Sch., 487 N.W.2d 857, 865 (Minn. 1992).

“[E]ducating young people in their faith, inculcating its teachings, and training them to live

their faith are responsibilities that lie at the very core of the mission of a private religious

school.” Our Lady of Guadalupe, 591 U.S. at 753-54. In short, “[i]n the Catholic tradition,

religious education is intimately bound up with the whole of the Church’s life.” Id. at 754

(quotations omitted).

Consistent with the mission of a private religious school, and as acknowledged in

MoChridhe’s complaint, “[t]he mission of [Holy Angels] is to educate and nurture a diverse

student population,” and the media specialist/librarian “collaborates with the professional

staff to support the mission of the Academy of Holy Angels.” Although MoChridhe

acknowledges—in her complaint—that as the media/specialist, she was expected to

“collaborate[] with the professional staff to support the mission of the Academy of Holy

16
Angels,” MoChridhe nonetheless informed Holy Angels’ principal that she could not abide

by the directives in the Guiding Principles.

In short, MoChridhe asks the judiciary to require the Archdiocese to employ a

person who does not support and will not abide by the church’s faith-based Guiding

Principles in the school setting, despite the Archdiocese’s internal decision to require

adherence to those principles when executing its mission to educate students in the Catholic

faith. MoChridhe does not cite, and we are not aware of, any case that compels that result

in the face of a church’s religious protections under the First Amendment. Again, training

young people to live their faith “lie[s] at the very core of the mission of a private religious

school.” Our Lady of Guadalupe, 591 U.S. at 753-54. Given the significant role that the

Catholic faith plays in Catholic education and the church’s mission to train young people

to live the Catholic faith, requiring the Archdiocese to employ a person in its Catholic

school who admittedly cannot abide by the church’s implementation of its Guiding

Principles in that school would interfere with an internal church decision that affects the

faith and mission of the church itself. Cf. Hill-Murray, 487 N.W.2d at 866 (stating that

under the Minnesota Constitution, although a Catholic high school could be subject to the

Minnesota Labor Relations Act, the school retained “the power to hire employees who

meet their religious expectations, to require compliance with religious doctrine, and to

remove any person who fails to follow [its] religious standards”).

The principle that a claim against a church is foreclosed if a court’s adjudication of

the claim would interfere with an internal church decision that affects the faith and mission

of the church itself is substantially similar to a related principle: a state action must not

17
foster excessive governmental entanglement with religion. See Pfeil, 877 N.W.2d at 537

(describing the related principles and applying both). MoChridhe’s complaint is clear: she

seeks to entangle church and state in a way that is constitutionally intolerable. In her

request for relief, MoChridhe requests:

1. That the practices of Defendants complained of
herein be adjudged, decreed, and declared to be in violation of
the rights secured to Plaintiff by the . . . [MHRA].
2. That a permanent injunction be issued prohibiting
Defendants from engaging in the practices complained of
herein.
3. That the Court order Defendants to pay a civil penalty
to the State of Minnesota pursuant to Minn. Stat. § 363A.29.
4. That Plaintiff be awarded compensatory damages in
an amount greater than $50,000.
5. That Plaintiff be awarded treble damages pursuant to
Minn. Stat. §§ 363A.33 and 363A.29.
6. That Plaintiff be awarded punitive damages pursuant
to Minn. Stat. § 363A.29 in an amount to be determined at trial.
7. That the Court issue an order enjoining Defendants
and their officers, agents, and employees from subjecting
Plaintiff to differential treatment and from any retaliation
against Plaintiff for prior actions, or for bringing this action.
8. That the Court retain jurisdiction until the Court is
satisfied that the Defendants have remedied the practices
complained of herein and are determined to be in full
compliance with the law.

(Emphasis added.)

In sum, MoChridhe asks the Minnesota judiciary to issue a secular judgment

decreeing the Archdiocese’s implementation of Catholic doctrine in Catholic schools

illegal, to monitor the Archdiocese until the Minnesota judiciary is “satisfied” that the

Archdiocese has abandoned the allegedly illegal implementation of its religious doctrine

in its Catholic schools, and to financially sanction the Archdiocese for adhering to its faith-

18
based beliefs when making employment decisions in a Catholic school setting. Granting

such relief would be fundamentally at odds with the religious freedoms protected by the

First Amendment, as envisioned by our founding fathers. See Hosanna-Tabor Evangelical

Lutheran Church & Sch. v. E.E.O.C., 565 U.S. 171, 183, 194 (2012) (describing historical

background against which the First Amendment was adopted, holding that the First

Amendment required dismissal of an employment-discrimination suit against a religious

employer, and stating that an award of financial relief “would operate as a penalty on the

Church for terminating an unwanted minister, and would be no less prohibited by the First

Amendment than an order overturning the termination”).

The government may not compel a church to conform its sincerely held religious

beliefs to those of the government. See Geraci v. Eckankar, 526 N.W.2d 391, 399 (Minn.

App. 1995) (“If courts begin to question a church’s basis for doctrinal decisions, a church

may be compelled to conform its religious beliefs with the government’s or the majority

culture’s beliefs.”), rev. denied (Minn. Mar. 14, 1995). “[A]ny attempt by government to

dictate or even to influence [matters of faith and doctrine] would constitute one of the

central attributes of an establishment of religion,” which “the First Amendment outlaws.”

Our Lady of Guadalupe, 591 U.S. at 746. MoChridhe seeks to do exactly that. The First

Amendment does not allow it.

MoChridhe’s Arguments

MoChridhe makes five arguments in support of her contention that her lawsuit does

not violate the First Amendment and should not have been dismissed. None is persuasive.

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 1.

MoChridhe argues that the church autonomy doctrine does not foreclose her lawsuit

for the following reasons: (1) she “is a lay employee who brought colorable claims of

discrimination and negligence under neutral and generally applicable laws,” (2) she “was

neither qualified nor expected to minister the Catholic faith or to be a member of the

Catholic church,” and (3) she does not challenge the Archdiocese’s “interpretation of

scripture and does not raise a dispute over church property, church membership or

excommunication, nor does she ask a court to resolve any such dispute.”

Although MoChridhe has identified some factual differences between this case and

precedent, we are not persuaded that those differences require a conclusion that judicial

resolution of MoChridhe’s claims would not unconstitutionally intrude on the autonomy

of the Catholic Church or entangle the church and state in way that is constitutionally

intolerable. The factual differences merely present a need to apply precedent to a set of

facts not previously considered. Under the facts and circumstances of this case, application

of precedent supports a conclusion that MoChridhe’s claims cannot be adjudicated by the

judiciary without violating the religious freedom provisions of the First Amendment.

2.

MoChridhe argues that she asks the judiciary to determine only whether the MHRA

“prohibits a religious institution from firing a transgender person,” and “not whether a

religious institution, like [the Archdiocese], has properly interpreted its religious doctrine

20
when determining that a transgender person violates religious law and must be fired.”4 The

fact that we do not need to determine whether the Archdiocese has properly interpreted its

religious doctrine does not end our inquiry under the church autonomy doctrine. Again, a

court can resolve a dispute regarding a religious organization only if “the adjudication does

not interfere with an internal church decision that affects the faith and mission of the church

itself.” Pfeil, 877 N.W.2d at 534 (quotation omitted).

MoChridhe’s complaint alleges that the Guiding Principles were “the only reason”

for the employment decision that is at issue here. The Guiding Principles state that they

are “practically applied in Catholic schools.” And binding precedent recognizes the

significant role that Catholic faith plays in the Catholic school setting. Adjudicating

MoChridhe’s claims would require the judiciary to interfere with an internal church

decision related to the church’s mission to train its Catholic school students to live

according to the Catholic faith. We cannot ignore the First Amendment implications of

MoChridhe’s lawsuit.

3.

MoChridhe argues that the federal constitution does not prohibit application of

neutral, generally applicable regulatory laws to religious litigants. She relies on

4
MoChridhe relies on federal district court and circuit court caselaw throughout her brief,
including Zinski v. Liberty University, Inc., 777 F. Supp. 3d 601 (W.D. Va. 2025).
Although we may consider such caselaw as persuasive authority, we are bound by
decisions of the Minnesota Supreme Court and the United States Supreme Court, and not
by the decision of any other federal court. Citizens for a Balanced City v. Plymouth
Congregational Church, 672 N.W.2d 13, 20 (Minn. App. 2003). We do not find the
nonbinding federal cases persuasive.

21
Employment Division, Department of Human Resources of Oregon v. Smith, 494 U.S. 872

(1990), superseded by statute, 42 U.S.C. §§ 2000bb to 2000bb-4 (Supp. 1993). The Smith

Court held that the denial of two Native American Church members’ claims for

unemployment benefits after they were fired from their jobs for ingesting peyote, a crime

under Oregon law, did not violate the Free Exercise Clause, even though the peyote had

been ingested for sacramental purposes. 494 U.S. at 874, 890. The Supreme Court stated

that the “right of free exercise does not relieve an individual of the obligation to comply

with a valid and neutral law of general applicability on the ground that the law proscribes

(or prescribes) conduct that his religion prescribes (or proscribes).” Id. at 879 (quotation

omitted).

But the Supreme Court limited application of Smith in Hosanna-Tabor, explaining:

It is true that the [Americans with Disabilities Act’s]
prohibition on retaliation, like Oregon’s prohibition on peyote
use, is a valid and neutral law of general applicability. But a
church’s selection of its ministers is unlike an individual’s
ingestion of peyote. Smith involved government regulation of
only outward physical acts. The present case, in contrast,
concerns government interference with an internal church
decision that affects the faith and mission of the church itself.

565 U.S. at 190. While we are mindful of the distinction between a religious minister and

a secular media specialist/librarian, we conclude that this case is like Hosanna-Tabor, and

not like Smith. This case concerns government interference with an internal church

decision that affects the faith and mission of the church itself, and not a criminal act. Smith

is further distinguishable because it did not involve a religious employer and did not raise

the same concerns that are at issue here. See Smith, 494 U.S. at 874.

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 4.

MoChridhe argues that this case cannot be resolved with a dismissal under Minn.

R. Civ. P. 12.02(e) because the factual record is inadequately developed. As to application

of the church autonomy doctrine, we disagree. We accept the factual allegations in

MoChridhe’s complaint as true. Those allegations include that MoChridhe was not offered

a renewed employment agreement with Holy Angels only because she informed Holy

Angels that she could not abide by the directives in the Guiding Principles, as applied in

the school setting. Those facts, as pleaded, establish that litigation of her claims and

imposition of her request for relief would violate the First Amendment. Because the

relevant facts are undisputed in this procedural posture and the First Amendment

determination is one of law, dismissal is not premature. See Hoskin v. Krsnak, 25 N.W.3d.

398, 400-01 (Minn. 2025) (holding that, in the context of an affirmative defense, a motion

to dismiss may be granted if the allegations in the complaint, construed in plaintiff’s favor,

establish an unrebuttable defense); see also Pfeil, 877 N.W.2d at 530 (affirming the district

court’s dismissal under the church autonomy doctrine).

5.

Finally, MoChridhe argues regarding the relevance of the “ministerial exception” in

this case. Under that exception, churches and religious organizations are categorically

exempt from compliance with employment-discrimination statutes when making decisions

regarding ministerial employees. Hosanna-Tabor, 565 U.S. at 185-89.

MoChridhe argues that even though the Archdiocese did not raise the ministerial

exception in district court, “it is difficult to discuss the interaction between anti-

23
discrimination law and religious liberties . . . without discussing the ministerial exception”

and that “dismissal based on the ministerial exception is unwarranted.” The Archdiocese

responds that the ministerial exception is “a derivative of” the broader church autonomy

doctrine. See Pfeil, 877 N.W.2d at 534 (stating the same). The Archdiocese argues that

the ministerial exception applies to a defined group of employees of a religious

organization, that is, “ministers,” and that “another area of church autonomy applies to all

employees of a religious organization—minister or not.” In sum, the parties dispute

whether the ministerial exception is the only way a religious employer can obtain First

Amendment religious protections against an employment-discrimination claim.

The Archdiocese did not request dismissal under the ministerial exception in the

district court, and the district court did not consider application of that exception when

dismissing MoChridhe’s claims. “A reviewing court must generally consider only those

issues that the record shows were presented [to] and considered by the trial court in

deciding the matter before it.” Thiele v. Stich, 425 N.W.2d 580, 582 (Minn. 1988)

(quotation omitted). However, that is not “an ironclad rule.” Oanes v. Allstate Ins. Co.,

617 N.W.2d 401, 403 (Minn. 2000). Because there are no factual disputes that affect the

purely legal question of whether First Amendment protections are available in this case

only under the ministerial exception, we will briefly address the issue. See Minn. R. Civ.

App. P. 103.04 (stating that an appellate court may “review any other matter as the interest

of justice may require”).

The Supreme Court has not expressly addressed this issue. Its seminal cases are

Hosannah-Tarbor and Our Lady of Guadalupe. In Hosanna-Tabor, the Supreme Court

24
considered whether the First Amendment bars a terminated employee’s employment-

discrimination claim against a religious employer when the employee is one of the

employer’s ministers. 565 U.S. at 176. The Court noted that the federal appellate courts

had uniformly recognized the existence of a “ministerial exception” under the First

Amendment and that the exception had been relied on to preclude application of

employment-discrimination laws “to claims concerning the employment relationship

between a religious institution and its ministers.” Id. at 188. The Supreme Court agreed

that there is such an exception. Id. But the Court did not “adopt a rigid formula for deciding

when an employee qualifies as a minister.” Id. at 190, 196.

Although the Hosanna-Tabor Court determined that the exception applied in that

case, noting that the case concerned “government interference with an internal church

decision that affects the faith and mission of the church itself,” the Court did not address

whether the religious protections of the First Amendment are available to a religious

employer defending an employment-discrimination claim by a non-minister who was

terminated for religious reasons. Id. at 190.

In Our Lady of Guadalupe, the Supreme Court extended the reach of the ministerial

exception, stating that “whether a particular position falls within the . . . exception, a

variety of factors may be important.” 591 U.S. at 751. “What matters, at bottom, is what

an employee does.” Id. at 753. Again, the Court did not address whether the religious

protections of the First Amendment are available to a religious employer defending an

employment-discrimination claim by a non-minister who was terminated for religious

reasons.

25
 In Our Lady of Guadalupe, Justice Sotomayor wrote a dissenting opinion, joined by

Justice Ginsburg, criticizing the majority’s expansion of the ministerial exception. The

dissent noted that, when the exception applies, it is “extraordinarily potent” and “gives an

employer free rein to discriminate because of race, sex, pregnancy, age, disability, or other

traits protected by law when selecting or firing their ‘ministers,’ even when the

discrimination is wholly unrelated to the employer’s religious beliefs or practices.” Id. at

767 (Sotomayor J., dissenting) (emphasis added). The relevance of a religious reason for

a religious employer’s alleged employment discrimination was stressed throughout the

dissenting opinion. Id. at 766-85 (Sotomayor J., dissenting). Justice Sotomayor wrote that

Hosanna-Tabor’s “well-rounded approach ensured that a church could not categorically

disregard generally applicable antidiscrimination laws for nonreligious reasons.” Id. at

771-72 (Sotomayor J., dissenting) (emphasis added).

So long as the employer determines that an employee’s duties
are vital to carrying out the mission of the church, then today’s
laissez-faire analysis appears to allow that employer to make
employment decisions because of a person’s skin color, age,
disability, sex, or any other protected trait for reasons having
nothing to do with religion.

Id. at 784 (Sotomayor J., dissenting) (emphasis added) (quotations and citation omitted).

Finally, the dissent asserted that the majority’s decision “permit[ed] religious entities to

discriminate widely and with impunity for reasons wholly divorced from religious beliefs.”

Id. at 784-85 (Sotomayor J., dissenting) (emphasis added).

The dissent’s emphasis on a church’s ability to obtain First Amendment protection

from a discrimination claim by a terminated employee based only on a determination that

26
the employee was a “minister”—despite the absence of any underlying religious reason for

the employee’s termination—begs the question: Does the First Amendment protect a

religious employer from discrimination claims by a terminated non-minister employee if

the termination was based on a religious reason? Given the facts alleged in MoChridhe’s

complaint and the absence of any binding precedent suggesting otherwise, we discern no

basis to conclude that the broader religious protections of the First Amendment church

autonomy doctrine are not available to the religious employer in that situation. Cf. Bostock

v. Clayton Cnty., Georgia, 590 U.S. 644, 682 (2020) (recognizing discrimination based on

transgender status as discrimination based on sex under Title VII and that religious freedom

issues were likely to follow stating, “while other employers in other cases may raise free

exercise arguments that merit careful consideration, none of the employers before us today

represent in this Court that compliance with Title VII will infringe their own religious

liberties in any way”).

As this case shows—on the face of MoChridhe’s complaint—the decision not to

offer her renewed employment at Holy Angels was based only on a religious reason: her

stated inability to abide by the directives in the Guiding Principles, as applied in the school

setting. Thus, consideration of MoChridhe’s claims would require consideration of the

Archdiocese’s religious reason for the employment decision, would interfere with the

Archdiocese’s internal decision to require compliance with the Guiding Principles in the

school setting—which relates to the church’s mission to educate young people in its faith—

and would foster excessive governmental entanglement with religion. The potential

27
inapplicability of the ministerial exception does not change that conclusion, and there is no

precedent indicating that it must.5

In conclusion, we recognize the apparent tension between the government’s interest

in eliminating discrimination and the religious freedoms protected by the First

Amendment. “The interest of society in the enforcement of employment discrimination

statutes is undoubtedly important. But so too is the interest of religious groups in choosing

who will preach their beliefs, teach their faith, and carry out their mission.” Hosanna-

Tabor, 565 U.S. at 196 (emphasis added); see Geraci, 526 N.W.2d at 399 (“There is a

tension between eradicating discrimination and permitting the free exercise of religion;

however, in this case, the balance weighs in favor of the First Amendment.”).

Based on our application of precedent to the particular facts of this case—as alleged

in MoChridhe’s complaint—we hold that because the allegations in MoChridhe’s

complaint, construed in her favor, establish that the district court’s adjudication of her

claims would violate the religious protections of the First Amendment as a matter of law,

the district court properly dismissed MoChridhe’s employment discrimination claims

against the Archdiocese for failure to state a claim under Minn. R. Civ. P. 12.02(e).

DECISION

Because the allegations in MoChridhe’s complaint would interfere with an internal

church decision that affects the Archdiocese’s faith-based mission to educate young people

in the Catholic faith and would foster excessive governmental entanglement with religion,

5
Because the Archdiocese did not rely on the ministerial exception in district court, we do
not consider or determine whether the exception applies in this case.

28
the district court properly dismissed those claims under Minn. R. Civ. P. 12.02(e) based on

the First Amendment. Because all MoChridhe’s claims are foreclosed by the religious

freedom provisions in the First Amendment to the United States Constitution, we do not

consider her arguments regarding the alternative grounds on which the district court based

its dismissal (i.e., the Minnesota Constitution’s Freedom of Conscience Clause and the

MHRA’s religious-association exemption under Minn. Stat. § 363A.26).

Affirmed.

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