In Fratello v. Archdiocese of New York, the Second Circuit Court of Appeals provided important guidance on determining whether or not an employee may be classified under the “ministerial exception.”  The “exception” precludes employees who may be classified as a “minister” from making employment discrimination claims against the religious entities that employ them. A “minister” is determined by evaluating, among other things, the employee’s formal title, the substance reflected in the title, the employee’s use of the title, and the important religious functions performed.