Although the court declined to adopt a "rigid formula" to determine who is a minister, it found compelling that Ms. Perich (1) was held out as a minister and given a formal ministerial title, (2) had undergone a "significant degree of religious training" in order to obtain that title, (3) held herself out as a minister, even claiming special housing allowances for ministers on her taxes, and (4) performed significant religious functions, including playing "a role in conveying the Church's message and carrying out its mission." The entire court agreed with this outcome, but Justices Samuel Alito and Elena Kagan wrote separately to stress that the last factor the majority cited--whether the employee functions as a minister, including "those who serve in positions of leadership, those who perform important functions in worship services and in the performance of religious ceremonies and rituals, and those who are entrusted with teaching and conveying the tenets of the faith to the next generation"--should be the touchstone of the analysis. Otherwise, they feared that a strict application of the other factors would hinder religious traditions without concepts of ministerial status or ordination from claiming the exception.Justice Clarence Thomas also wrote separately, noting that his preferred standard for who should qualify as a minister would "defer to a religious organization's good-faith understanding." Since "Hosanna-Tabor," scholars have continued to debate the exception. Even with the guidance of "Hosanna-Tabor", lower courts have struggled with the standard for who should qualify as a minister. While some courts have hewed closer to Justice Alito and Kagan's function-centric standard, others have declined to apply the exception when employees like teachers function as ministers in some broad sense, but hold no other indicia of ministerial status. The Ninth Circuit has typified this approach. In "Biel v. St. James School," the court declined to use the exception to bar the disability-discrimination suit of an elementary school teacher who "taught religion for about thirty minutes a day, four days a week, using a workbook on the Catholic faith." The court held similarly in "Morrissey-Berru v. Our Lady of Guadalupe School", allowing a Catholic elementary school teacher's age discrimination suit to move forward. Both the "Biel" and "Morrissey-Beru" decisions were appealed to the Supreme Court, which granted certiorari and consolidated the cases on December 18, 2019. Oral arguments were held via phone on May 11, 2020 due to the COVID-19 pandemic.