Since Hosanna-Tabor did not address how to decide if an employer is "religious," should the Court review this case and define the proper analysis in determining the necessary extent or scope of an institution's "religious" activities or character in order for it to invoke the "ministerial exception?"

2. Is the Second Circuit's opinion contrary to Hosanna-Tabor and Circuit Court precedent by holding that NYMH's operation of an ecumenical chaplain department makes it a "religious" hospital, despite its renunciation of its affiliation with the United Methodist Church, its removal of the requirement to maintain "its Christian genesis and its Church related character" from its Purpose and its being avowedly secular overall?

3. Can an avowedly secular hospital, such as NYMH, avoid anti-discrimination laws simply by employing ecumenical chaplains, especially where allowing Penn to sue NYMH in this case does not excessively entangle the courts in any religious issues?

Whether the ministerial exception applies to an avowedly secular hospital that employs an ecumenical chaplain