Gonzalez v. Roman Catholic Archbishop of Manila and Its Contributions to American Civil Church Law

The tension between the religion clauses of the First Amendment to the United States Constitution, guaranteeing the nonestablishment of religion and prohibiting the restriction of its free exercise, is clearest when secular courts are cal led upon to adjudicate the internal disputes of religious organizations. Such a d ispute was at th e heart of the 1929 case o f Gonzalez v. Roman Catholic Archbishop of Manila, in which the plaintiff alleged his right to be appointed to an ecclesiastical benefice in accordance with the terms of the canon law in force at the time of its erection rather than the more stringent provisions of the 1917 Code of Canon Law then in force. A minor milestone in the development of principles for the resolution of church disputes by secular courts, Gonzalez’s greater significance lies in its status as a forerunner of the ministerial exception, the legal doctrine which immunize s “religious entities from discrimination suits brought by employees with ‘ministerial’ responsibilities such as teaching religious doctrine or leading worship.

Perceptions of Discrimination Among Women as Managers In Hospitality Organizations

Women in hospitality organizations are moving up the corporate ladder at a pace significantly outdistancing their colleagues of a few decades ago, but women managers selectively perceive overt and covert discriminatory resistance, from chauvinism to carefully-contrived covert prejudicial treatment constructed to insure a no-win situation. The authors attempted to determine if these discriminatory practices against equally well-trained, qualified, and experienced hospitality women middle managers do affect their perception of their career growth as compared to male counterpart