The Holy Bible, Matthew 18:15-17 (New American Standard Bible). 2 . The National Association of Evangelicals, the Southwestern Baptist Theological Seminary, and Dallas- Theological Seminary submitted amicus curiae briefs in support of Westbrook’s petition. 3 . Most courts agree that the general prohibition on the adjudication of religious questions, once triggered, precludes further adjudicatio 5 n. 10 (Colo.1988) (" 'Family counseling and psychological counseling are two notable areas in which there is substantial overlap between the secular and religious aspects of a spiritual counselor’s activities.’") (quoting Note, Clergy Malpractice: Taking Spiritual Counseling Conflicts Beyond Intentional Tort Analysis, 19 Rutgbrs L.J. 419, 437 (1988)), and citing Comment, Mad (5th Cir.1972) (<HOLDING>); c/1 Scotts African Union Methodist Protestant
recognizing that the relationship between an organized church and its ministers is its lifeblood and that application of title vii to this relationship would encroach on religious freedom holding claims based on title vii subject to arbitration holding that a claim for discrimination in private employment is not preempted by title vii holding application of title vii to the employment relationship between the salvation army and its ordained minister would involve a review that would cause improper state intrusion on matters of church governance recognizing title vii does not provide the exclusive remedy for all employment discrimination claims even if the title vii and section 1983 claim factually overlap