Nor is there any requirement, as Grussgott seems to think, that a religious institution employ "ordained clergy" at the head of an "ecclesiastical hierarchy." Such a constraint would impermissibly favor religions that have formal ordination processes over those that do not. S

Based on the pleadings here, some circumstances weigh in favor of considering the board positions ministerial. The complaint alleges that a "mission and purpose" of SSSC and UI is "to benefit the Sikh Dharma community and to advance and promote [Yogi Bhajan's] teachings," and it is "surely relevant" that their board members must be ordained ministers of Sikh Dharma and must meet certain other religious criteria. See id. at 708. But, based on the face of the complaint, a number of other circumstances weigh against applying the ministerial exception. First, and most importantly, the pleadings do not allege the board members have any ecclesiastical duties or privileges. In assessing the responsibilities attendant to the board positions, it is relevant that the entities involved are not themselves churches, but rather corporate parents of a church. SSSC's primary responsibility appears to be holding title to church property, and UI, in addition to being the sole member of SDI — i.e., the direct corporate parent of the Sikh Dharma church — owns and controls a portfolio of for-profit and nonprofit corporations, including a major security contractor and a prominent tea manufacturer. Although the complaint alleges the board members have "fiduciary duties to UI and SSSC to hold assets in trust for the benefit of the Sikh Dharma community," it is not clear on the face of the complaint that these duties are "religious" or "reflect[] a role in conveying the Church's message and carrying out its mission." Id.

The Supreme Court has provided some guidance on the circumstances that might qualify an employee as a minister within the meaning of the ministerial exception. First, an employee is more likely to be a minister if a religious organization holds the employee out as a minister by bestowing a formal religious title. See id. at 707. Although an ecclesiastical title "by itself, does not automatically ensure coverage, the fact that an employee has been ordained or commissioned as a minister is surely relevant." Id. at 708. A second consideration is the "substance reflected in that title," such as "a significant degree of religious training followed by a formal process of commissioning." Id. at 707-08. Third, an employee whose "job duties reflect[] a role in conveying the Church's message and carrying out its mission" is likely to be covered by the exception, even if the employee devotes only a small portion of the workday to strictly religious duties and spends the balance of her time performing secular functions. Id. Finally, an employee who holds herself out as a religious leader is more likely to be considered a minister. Id.

comedy as a platform for advancing social justice

“comedy and satire possess a common denominator in that both try to change or reform society by means of humour. The two forms together constitute the best illustration there is of the social function of humour.”