Press Release

Indiana court upholds religious freedom for Catholic schools Government can’t meddle in religious standards for Catholic teachers

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Ryan Colby 202-349-7219

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WASHINGTON – An Indiana trial court today issued an important ruling in favor of the Archdiocese of Indianapolis, confirming its right to ensure students and families receive an authentic Catholic education. In Payne-Elliot v. Archdiocese of Indianapolis, a former Catholic high school teacher sued the Archdiocese after he was dismissed for entering a same-sex union in violation of his contract and millennia of Church teaching. The trial court initially ruled that the lawsuit could move forward, but the Indiana Supreme Court sent the case back down and authorized the trial court to reconsider. The court then threw out the entire case, vindicating the Archdiocese’s constitutional right to set religious standards for its schools.

Every Catholic school teacher in the Archdiocese of Indianapolis signs an agreement to uphold the teachings of the Catholic Church in word and deed. In 2017, Joshua Payne-Elliott, who taught at Cathedral Catholic High School in Indianapolis, entered a same-sex union in violation of both his employment agreement and centuries of Catholic teaching. After an extensive period of discernment and dialogue, the Archdiocese of Indianapolis informed Cathedral High School that if it wanted to remain affiliated with the Catholic Church, it needed to require its teachers to uphold Church teaching. After Cathedral separated from Mr. Payne-Elliott and provided him with a settlement, he sued the Archdiocese.

“If the First Amendment means anything, it means the government can’t punish the Catholic Church for asking Catholic educators to support Catholic teaching,” said Luke Goodrich, vice president and senior counsel at Becket, which is representing the Archdiocese. “This has always been a very simple case, because the Supreme Court has repeatedly affirmed the freedom of religious schools to choose teachers who support their religious faith.”

The Supreme Court has long recognized that the Constitution protects the personnel decisions of churches and religious schools. The Court’s most recent decision came earlier this year in Becket’s landmark cases, Our Lady of Guadalupe School v. Morrissey-Berru and St. James Catholic School v. Biel, in which the Supreme Court affirmed the right of religious organizations to “autonomy” in matters of faith, doctrine, and internal governance. Prior to that, the Supreme Court unanimously affirmed the same right in EEOC v. Hosanna-Tabor Evangelical Lutheran Church and School, another Becket case. Today, the Indiana court applied that principle and affirmed that the government has no business interfering in religious standards at religious schools.

In September 2020, both the United States Department of Justice and the State of Indiana filed briefs in the case, arguing that “settled law on the church-autonomy doctrine makes clear that the First Amendment prohibits the [lawsuit].” It is not yet clear if the plaintiff intends to appeal.

For more information or to arrange an interview with a Becket attorney, contact Ryan Colby at or 202-349-7219. Interviews can be arranged in English, Chinese, French, German, Portuguese, Russian, and Spanish.