Fratello v. Roman Catholic Archdiocese

175 F. Supp. 3d 152, 2016 U.S. Dist. LEXIS 41483, 2016 WL 1249609
CourtDistrict Court, S.D. New York
DecidedMarch 29, 2016
DocketNo. 12-CV-7359 (CS)
StatusPublished
Cited by6 cases

This text of 175 F. Supp. 3d 152 (Fratello v. Roman Catholic Archdiocese) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Fratello v. Roman Catholic Archdiocese, 175 F. Supp. 3d 152, 2016 U.S. Dist. LEXIS 41483, 2016 WL 1249609 (S.D.N.Y. 2016).

Opinion

OPINION AND ORDER

Seibel, United States District Judge.

Before the Court are Defendants’ Motion for summary judgment, (Doc. 90), and Plaintiff’s Cross-Motion to strike Defendants’ ministerial-immunity defense, (Doc. 103). For the reasons set forth below, Defendants’ Motion is GRANTED and Plaintiffs Motion is DENIED.

1. BACKGROUND

The following facts are based on the parties’ Local Rule 56.1 statements1 and responses thereto, and supporting materials, and are undisputed except where noted.

Plaintiff Joanne Fratello is a former principal of St. Anthony’s School (the “School”), a Catholic elementary school located in Nanuet, New York. (See Ds’ Counter 56.1 ¶ 13; AC ¶¶ 1, 12, 13, 19.)2 Defendants are the Archdiocese of New York (the “Archdiocese”), St. Anthony’s Shrine Church and the School. (AC ¶¶ 2, 5, 7.) Plaintiff served as principal of the School from 2007 until 2011, when her contract was not renewed for the 2011-2012 school year. (Ds’ Counter 56.1 ¶¶ 11, 21, 106.) Plaintiff alleges that the decision to terminate her employment was the result of gender discrimination and retaliation, and she now seeks relief in this Court. (AC ¶¶ 12-16.)

A. Factual Background

The School, which is chartered under the laws of New York, is run by the Arch[156]*156diocese. (Ds’ Counter 56.1 ¶ 31; AC ¶¶ 34-38, 114.) Before addressing the specifics of Plaintiffs employment, it is useful to examine the Archdiocese’s and the School’s mission statements and manual, as well as the role of its principals in the abstract.

1, The Mission and Manual of the Archdiocese of New York and St. Anthony’s School

The website of the Catholic Schools in the Archdiocese of New York proclaims that its mission is “to ensure [its] schools are Christ-centered, academically excellent, and welcoming communities that teach students to be life-long learners and leaders energized by fidelity to Christ, the Church, and one another.” (Novikoff Decl. Ex. A, at 2-3.)3 The Archdiocese’s website further describes the “Catholic school experience” as follows:

Our Catholic faith is central to what we do, and we proudly teach it. Gospel ideals permeate the substance and structure of our lessons. We share our faith through daily prayer and the regular celebration of Mass as a school community. We foster a spirit of Christian service as an expression of our concern for the needs of others. Character formation and personal spirituality are rooted in the study of Catholic teachings and tradition, as well as sacramental preparation. Our academic programs grounded in basic skills meet the varied needs of each school community by incorporating technology, advanced math, hands-on science, and foreign language coupled with the various forms of art study. We offer a forward-focused curriculum, integrating technology into classroom instruction, preparing our students to compete in an increasingly complex world.

(Id.) Similarly, the School’s mission is to “provide a high-quality, educational experience that enhances each child’s spiritual, emotional, intellectual and social growth. Our faculty and staff prepare our students to become future leaders and responsible stewards of God’s creation.” (See Ds’ Counter 56.1 ¶ 7.) Religion is a central part of the School curriculum. (See P’s Counter 56.1 ¶¶ 92-97.) At the same time, the School is required, by law, to provide its students with an education substantially equivalent to that of public schools. (Ds’ Counter 56.1 ¶ 72.)

The Archdiocese disseminates an Administrative Manual (the “Manual”) that delineates policies and procedures for principals and other administrator's. (See generally Admin. Manual.)4 In a cover letter for the Manual, addressed “Dear friends in the Lord,” Edward Cardinal Egan, Archbishop of New York at the time of the Manual’s issuance, wrote to principals:

As principals in the schools of the Archdiocese of New York, you are providing splendid leadership to your teachers and staff and excellent academic and spiritual formation to your students. This is demanding work, and I am deeply grateful for the wisdom and devotion with which you do it. With each passing year, it becomes more and more clear to our Catholic faithful and the community at large that we are all greatly in your debt.
This revised Administrative Manual is designed to assist you in the administrative tasks you must fulfill in providing the structure needed to carry out the vital work of Catholic education. The updated sections and materials give evidence of the growing demands required to provide the appropriate learning envi[157]*157ronment, and [sic] environment which enables each of our schools to offer quality academic education infused with the Catholic Faith and values that are so needed by the young people who come to us.
Again, I thank you for having accepted the vocation and challenge of leadership in Catholic education. Be assured of my prayers and support for your work which is so crucially important to the Church in New York.

(Admin. Manual at 023753.) Another letter within the Manual is addressed to principals from Michael Ramos, Associate Superintendent of Schools for Professional Recruitment, and states: “The Catholic school is essential to the Church in fulfilling its teaching mission.It is your responsibility as principal to establish a climate which is identifiably Catholic and which nurtures the growth of teachers and students in all dimensions of life.” (Id at 023923.)

The Manual also contains a job description for principals. It states:

The principal is the leader of the school, a unique Catholic educational institution. The principal is responsible for achieving the Catholic mission and purpose of the school as well as the quality of teaching and learning that goes on in the school. S/he is the animator of the community of faith within the school.
The principal must of necessity be involved in every aspect of the school operation. The principal oversees the areas of religious education, curricula instruction, formulation and communication of school policy, supervision of personnel, staff recruitment and development, student recruitment, maintenance of school records, discipline and co-curricular activities.

(id at 023924.) The Manual goes on to describe a principal’s role in providing “Catholic leadership” as follows:

The principal cooperates with the pastor in recruiting and maintaining a staff committed to the goals of a Catholic school; cooperates with the pastor in his religious ministry to the students; ensures adherence to the curriculum guidelines, Guidelines for Catechists,

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175 F. Supp. 3d 152, 2016 U.S. Dist. LEXIS 41483, 2016 WL 1249609, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fratello-v-roman-catholic-archdiocese-nysd-2016.