Miriam Grussgott v. Milwaukee Jewish Day School, Inc.

Does the definition of "religious institution" in the two prong test for "ministerial exception" in Hosanna- Tabor Evangelical Lutheran Church and Sch. v. E.E.O.C., 565 U.S. 171, 132 S.Ct. 694, 709, 181 L.Ed. 2d 650 (2012) (hereinafter "Hosanna ") require that the "religious institution" be "faith-based" and have at its head to hire and fire either a certified, ordained or lay "minister" and/or a hierarchy of such ministers, or is it sufficient for the "religious institution" to be an institution administered in hiring and firing by totally lay people with absolutely no ministerial certification, formal or informal, and with no hierarchy whatsoever of ministers, as in Grussgott v. Milwaukee Jewish Day School, Inc., 882 F.3d 655 (2018) (hereinafter "Grussgott", which the Seventh Circuit has held in this case? Does the "ministerial exception" require a) religious "experience" as opposed to religious "training", as held by the Seventh Circuit in Grussgott and contrasted in Shaliehsabou v. Hebrew Home of Greater Washington, Inc., 363 F.3d 299 (2004); b) religious teaching and job descriptions that are "tasked" Hosanna-Tabor at 132 S.Ct. 694, 708, as opposed to "volunteered"; and c) teaching with a cultural, historical perspective, which was held to be ministerial under the "ministerial exception" as the Seventh Circuit held in this case Grussgott, as opposed to "faithbased" teaching, leading and supervising, under the Sixth Circuit in Alyee T Conlon v. Intervarsity Christian Fellowship/USA. 777 F.3d 829 (6th Cir. 2015)