Cunningham Dalman secured a big win for one of its clients in the Sixth Circuit Court of Appeals. Aaron Pulsifer v. Westshore Christian Academy, No. 24‑2092 (6th Cir. July 9, 2025)
The Sixth Circuit upheld dismissal of racial and sex discrimination claims brought by a former Dean/Assistant Principal whose duties included both administrative and explicitly religious functions.
Link to decision here.
Pulsifer, an African American male, claimed he served since 2019 as Dean of Students and Assistant Principal at a private Christian school in Muskegon Heights, MI. His responsibilities went beyond administration—they included leading devotions, praying with staff and board members, and managing after‑school and Sunday religious programs. After termination in August 2022, Pulsifer alleged discrimination based on race and sex, and retaliation after he raised concerns about pay disparities and a school funder. It should be noted, although it was not considered by the court, that Pulsifer is currently serving a multi-year sentence for fraud against the State of Michigan related to COVID funds.
Watch Video Here.
The administration of Westshore Christian Academy was offended by the claims Pulsifer alleged. While the decision does not address the merits of his claims, Westshore Christian Academy is satisfied with the decision that emphasized the separation between Church and State. The school is committed to offering low-cost Christian education to children in the Muskegon area.
1. Procedural Challenge: Pulsifer argued the district court denied a fair chance to respond when it converted the Academy’s dismissal motion into summary judgment. The Sixth Circuit ruled that a 14-day window satisfied Rule 12(d), and Pulsifer failed to request more time or discovery.
2. Ministerial Exception Scope: Did his blend of secular and religious duties bring him under the exception?
Relying on precedent, the court emphasized functional analysis over titles: what Pulsifer did mattered more than what his role was called. His leadership in daily devotions, prayers, and youth ministries—on top of secular tasks—was “vital” to the school’s religious mission. As a result, the court ruled his position fit squarely within the constitutional shield of the ministerial exception.
What It Means:
For Religious Institutions:
- Confirms that ‘hybrid roles’ (admin + spiritual) are protected.
- Employers should document religious responsibilities clearly in job descriptions.
- Mission statements and affidavits can be powerful tools in early summary-judgment stages.
For Employees & Litigators:
- Mere secular duties don’t exempt religious roles from the exception.
- Could prompt focus on genuinely secular jobs or pretextual terminations.
- Expect more careful role structuring and early legal positioning.
For the Sixth Circuit:
- Affirms autonomy of religious organizations in personnel decisions.
- Signals confidence in applying ministerial exception to dual-role staff.
- May influence similar decisions in other circuits.
Need Help Navigating Religious Employment Law?
If your organization grapples with discrimination claims—or you’re a staff member in a religious institution with mixed duties—our team can help:
For institutions: We can advise on drafting robust job criteria and defensive strategies.
For individuals: We evaluate whether ministerial exceptions apply and explore alternative legal avenues.
Contact us for a consultation tailored to religious‑employment law complexities.
Pulsifer v. Westshore Christian Academy strongly reinforces the ministerial exception’s application to hybrid administrative-religious positions. For religious organizations and their employees within the Sixth Circuit, the ruling is a clear directive—focus on substantive religious duties, not labels, when crafting and defending roles.
