Pulsifer v. Westshore Christian Academy

Aaron Pulsifer (plaintiff) was the assistant principal and dean of students at Westshore Christian Academy (Westshore) (defendant), a private elementary school in Michigan with the mission of helping students to grow their relationship with Christ, become lifelong learners, serve their communities, and develop Christian leadership skills. In his roles, Pulsifer performed many routine administrative and educational tasks. He also performed several religious functions. Westshore required the person in Pulsifer’s role to be a spiritual leader to students and staff. Pulsifer implemented and led two religious youth groups, prayed with staff and students, and led daily staff devotionals as well as devotionals at school-board meetings. Eventually, the relationship between Pulsifer and Westshore’s administrator deteriorated. Pulsifer, a Black male, complained that Westshore often withheld his paychecks despite regularly paying White, female coworkers. Pulsifer also claimed that Westshore treated the White coworkers better than him and expressed concern that he believed the school’s main donor to be a sex offender. After Westshore fired Pulsifer, Pulsifer sued Westshore for alleged violation of various state and federal laws prohibiting employment discrimination, including Title VII of the Civil Rights Act of 1964. Westshore argued that judicial review of Pulsifer’s claims was precluded by the ministerial exception because Pulsifer had performed important religious functions at the school. The district court granted summary judgment in Westshore’s favor, agreeing that the ministerial exception applied. Pulsifer appealed.