Dissenting Opinion by
HARRELL, Judge,which RAKER and CATHELL, JJ., Join.
I respectfully dissent. The Majority opinion, in the process of minimizing the role played by Moersen as the organist for St. Catherine Labouré Parish (“the Parish”), as compared to more extensive musical ministry and other ecclesiastical positions examined by other courts, lost sight of the simple reality that because Moersen’s “primary duties consisted] of ... participation in religious ritual and worship, he ... should be considered ‘clergy.’ ” Rayburn v. Gen. Conf. of Seventh-Day Adventists, 772 F.2d 1164, 1169 (4th Cir.1985); accord Montrose Christian Sch. Corp. v. Walsh, 363 Md. 565, 590, 770 A.2d 111, 126 (2001). This is true regardless of whether one relies on the duties delineated in Moersen’s employment contract, or the activities Moersen professes he actually performed as an *670employee. Accordingly, I believe that this Court should have accepted the Archdiocese of Washington’s argument invoking the “ministerial exception” to the prosecution of Moersen’s Title VII cause of action, reversed the judgment of the Court of Special Appeals, and affirmed the Circuit Court’s grant of summary judgment.
I. The “Ministerial Exception”
As the Majority opinion necessarily acknowledges, there exists a “ministerial exception” to the application of the employment anti-discrimination measures codified in Title VII of the Civil Rights Act of 1964. 42 U.S.C. § 2000e-l(a). The U.S. Supreme Court upheld, against Establishment Clause attack, this exception in Corporation of Presiding Bishop v. Amos, 483 U.S. 327, 107 S.Ct. 2862, 97 L.Ed.2d 273 (1987), and this Court also adopted it in Montrose Christian School Corp. v. Walsh. The aim of the exception is to honor the promise of the Free Exercise Clause by placing sectarian matters outside of the subject matter jurisdiction of secular courts. Bourne v. Ctr. on Children, Inc., 154 Md.App. 42, 54-55, 838 A.2d 371, 379 (2003).
The U.S. Court of Appeals for the Fourth Circuit declared that “[a]s a general rule, if the employee’s primary duties consist of teaching, spreading the faith, church governance, supervision of a religious order, or supervision or participation in religious ritual and worship, he or she should be considered ‘clergy.’” Rayburn, 772 F.2d at 1169 (quoting Bruce N. Bagni, Discrimination in the Name of the Lord: A Critical Evaluation of Discrimination by Religious Organizations, 79 Colum. L.Rev. 1514, 1545 (1979)); accord Montrose, 363 Md. at 590, 770 A.2d at 126. Rather than applying just to ministers and ordained clergy, the exception covers “any employee of a religious organization” engaged in the ministerial activities delineated by the Fourth Circuit in Rayburn. Montrose, 363 Md. at 590, 770 A.2d at 126; see also Equal Employment Opportunity Comm’n v. Roman Catholic Diocese of Raleigh, N.C., 213 F.3d 795, 802 (4th Cir.2000) (“[T]he exception has not been limited to cases involving ordained ministers or *671priests, but rather requires a fact-specific examination of the function of the position.”); see generally Serbian E. Orthodox Diocese for the U.S. & Canada v. Milivojevich, 426 U.S. 696, 96 S.Ct. 2372, 49 L.Ed.2d 151 (1976). The Rayburn court opined that “[t]his approach necessarily requires a court to determine whether a position is important to the spiritual and pastoral mission of the church.” 772 F.2d at 1169.
II. Moerseris Employment Contract Indicates Clearly that His Position is “Ministerial”
In order to determine whether a given employee’s position within a sectarian organization should be deemed “ministerial,” many courts have been guided either by the language contained in the employment contract binding the religious organization and the employee, or by the job description created by the religious organization in summarizing the duties of the employee.
In Diocese of Raleigh, the Fourth Circuit reviewed “[t]he various job descriptions for the music ministry positions, though not dispositive,” in ruling that a music director and music teacher at a Catholic church and elementary school fulfilled a ministerial role. 213 F.3d at 803. In Tomic v. Catholic Diocese of Peona, 442 F.3d 1036 (7th Cir.2006), Richard Tomic, a music director and organist for the Diocese of Peoria and St. Mary’s Cathedral, sued both entities for discrimination when he was dismissed from employment. Judge Posner, writing for the U.S. Court of Appeals for the Seventh Circuit, turned to the job descriptions developed by the diocese and the church for guidance in determining that Tomic’s position was truly ministerial. Tomic, 442 F.3d at 1037. In Scharon v. St. Luke’s Episcopal Presbyterian Hospitals, 929 F.2d 360 (8th Cir.1991), a federal appellate court was persuaded by the job description of a hospital chaplain in designating that employee’s position as ministerial. 929 F.2d at 362-63. In Starkman v. Evans, 198 F.3d 173 (5th Cir.1999), another federal appellate court utilized the job description of an employee’s position in its analysis of whether that position was ministerial. 198 F.3d at 176. In Shirkey v. *672Eastwind Community Development Corp., 941 F.Supp. 567 (1996), the U.S. District Court for the District of Maryland concluded that, based solely on the job description approved by the defendant religious organization, the position sought by a job applicant was not ministerial. 941 F.Supp. at 577-78. Another federal trial court, in Miller v. Bay View United Methodist Church, Inc., 141 F.Supp.2d 1174 (E.D.Wis.2001), relied on the job description provided by the church in ruling that an employee’s role was ministerial. 141 F.Supp.2d at 1181-82. Even in Assemany v. Archdiocese of Detroit, 173 Mich.App. 752, 434 N.W.2d 233 (1988), a case relied upon by the Majority opinion, the court took great pains to detail the contractual duties assigned to the organist, Assemany. 434 N.W.2d at 235-36. It was to those duties that the Assemany court looked in concluding that the organist position in that case was ministerial. 434 N.W.2d at 238.
A similar analytical approach is appropriate here. The case was disposed of in the Circuit Court on summary judgment. There was no genuine dispute between the parties as to Moersen’s contractual duties. The Majority opinion quotes Moersen’s employment contract with the Parish with respect to his duties as “Organist/PianisVKeyboard Accompanist:”
Job objectives:
To Support the Gospel message through the music ministry of Saint Catherine Laboure Church and to encourage the congregation to assume as active part in their musical participation at all liturgical parish functions.
Job description:
To provide Organ/Piano/Keyboard Music and/or musical accompaniment to both the congregation and the choirs of Saint Catherine Laboure Church at the 10:30 a.m., 12:00 noon and 1:15 p.m. Sunday services; to provide the same at the weekly Saturday 5:15 p.m. service; to provide same at special liturgical celebrations as listed below; to provide musical accompaniment for the congregation at the 7:00 p.m. Monday night weekly novena service.
2. Responsibilities of the organist:
*673a. To build and sustain congregational song at all liturgies.
b. To assist in selecting music associated with the worship at all liturgies in which he/she participates.
c. To assist in planning the music associated with the above mentioned liturgies.
d. To participate in special liturgical celebrations when requested, especially Christmas, Lenten and Easter liturgies, Confirmation, First Communion, and Reconciliation liturgies.
e. To work under the very general supervision of the choir directors of the Liturgical choir and the Hispanic Choir.
f. To attend parish staff meetings when appropriate.
3. Related job requirements:
a. The organist reports to the director of the choir concerning music and also has, as needed, access to the pastor who is ultimately the person to whom the organist must answer to regarding job related issues.
b. The organist shall be an ex officio member of all committees concerning liturgy.
c. The organist will accept engagements to assist at weddings and funerals and when he is unable to accept such engagements he will recommend suitable substitutes if he is asked to do so. The fees for these services will be a matter between the organist and the party requesting his services.
Maj. op. 339 Md. at 645-46, 925 A.2d at 663-64.
As to these duties and responsibilities, it is clear to me that Moersen’s position was of a ministerial nature. The objective of his position was “[t]o Support the Gospel message through the music ministry of Saint Catherine Laboure Church” and to encourage congregational participation in the liturgies though music. A position entailing the performance of religious music, for a church during its religious services, to a religious end cannot possibly be perceived as anything but religious. Moer*674sen’s contract tasked him with planning and playing music as an accompaniment to the religious hymns sung by the choir and the congregation. He was required to attend Parish staff meetings and was considered an ex officio member of all committees relating to the liturgies in which he performed. Under these circumstances, the contractual relationship between the Parish and Moersen steeped Moersen in duties and responsibilities “that primar[il]y ... consist of ... participation in religious ritual and worship----” Rayburn, 772 F.2d at 1169.
The Majority opinion, however, ignored the overtly religious duties assigned to Moersen and instead accepted Moersen’s characterization of his role at the Parish. Curiously, the Majority opinion, like the misguided intermediate appellate court here, neglected to consider the number of cases catalogued above where courts looked to the terms of an employee’s contract or the job description applicable to the employee’s position for guidance. The Majority opinion should not be allowed to escape the relevance of the employee’s job description being a stronger consideration. In surveying analogous cases, the Majority opinion itself recites from at least four cases where an employee’s job description was weighed explicitly by courts in making an assessment of whether a position was ministerial. Maj. op. 399 Md. at 649-52, 658-59, 665-66, 666-67, 925 A.2d at 666-67, 671, 675-76, 676 (citing Assemany, Diocese of Raleigh, Miller, and Starkman). Indeed, the Majority opinion is forced to acknowledge the religious nature of Moersen’s job description, yet sidesteps it unsatisfactorily by relying on Moersen’s incomplete job performance as reason, for purposes of its analysis, to ignore the religious duties the Parish entrusted to Moersen. Maj. op. 399 Md. at 656-57, 925 A.2d at 670 (“His contract to the contrary notwithstanding, the duties that the respondent actually performed, while they occurred during church services, were not ‘ministerial’ in any sense.”).
III. Moersen’s Role Solely as an Organist was Ministerial
Even with the Court majority confining its consideration to Moersen’s averment that he only played the organ, I nonethe*675less conclude that his position was a ministerial one. My opinion is compelled by nothing less than the simple reality that playing the organ for religious services at a Catholic church is an important facilitation of the liturgies in which Moersen participated, obviously an activity “important to the spiritual and pastoral mission of the church.” Rayburn, 772 F.2d at 1169.
Many jurisdictions have opined on the obvious sectarian significance of music as played during religious services. The Fourth Circuit, in Diocese of Raleigh, stated that it is an “undeniable fact that music is a vital means of expressing and celebrating those beliefs which a religious community holds most sacred.” 213 F.3d at 802; see also Starkman, 198 F.3d at 176 (“[T]here is no dispute that religious music plays a highly important role in the spiritual mission of the church.”); Tomic, 442 F.3d at 1041. There is also no shortage of facts adduced by the Archdiocese of Washington that music occupies a scared position in Catholic worship. In particular, the Archdiocese asserted that “the pipe organ is to be held in high esteem, for it is the traditional musical instrument that adds a wonderful splendor to the Church’s ceremonies and powerfully lifts up the spirit to God and to higher things.” Constitution on the Liturgy, Sacrosanctum Councilium, 4 December 1963. Despite this convincing evidence,1 both the Court of Special Appeals and the Majority in this Court downplay unsatisfactorily Moersen’s role.
The fact remains that because music inheres a vital liturgical significance, the performance of that music is equally as significant. Although Moersen contends that he is “just an organ player,” his apt performance of sacred and reverent music during worship services belies a secular characterization of his role. Moersen, as the organist, was an active participant in liturgies in a way that an organ manufacturer or a person who merely tunes the organ is not. See Tomic, 442 F.3d at 1041. Despite Moersen’s arguments, I am persuaded *676that there is no such thing as “just an organ player” in religious rituals and ceremonies such as those in which Moersen performed. I am not alone in this view.
In Tomic, Richard Tomic, a music director and organist, portrayed his involvement with his church employer in much the same manner as does Moersen here:
[s]o far as his role as organist is concerned, his lawyer says that all Tomic did was play music. But there is no one way to play music. If Tomic played the organ with a rock and roll beat, or played excerpts from Jesus Christ Superstar, at an Easter Mass, he would be altering the religious experience of the parishioners.
442 F.3d at 1040. In view of this reality, the Seventh Circuit held that “Tomic ‘performed tasks that were “traditionally ecclesiastical or religious.” ’ ” Tomic, 442 F.3d at 1041. In Diocese of Raleigh, the Fourth Circuit noted of a music director tasked with selecting and playing music for worship services that “even when Austin did not select the music herself, the subtle judgments that accompany the presentation and interpretation of sacred music contribute to its spiritual effect.” 213 F.3d at 803. The Diocese of Raleigh court then struck the same note as did the Tomic court in addressing the difficulty of accepting an argument such as Moersen’s that simply playing the organ has no religious importance:
Indeed, it is not easy to divorce even the more technical aspects of music from its significance in religious worship. Whether a selection is played adagio or andante can have a profound effect on the religious worship and vocal participation of the congregation. And different performances of the same musical piece can evoke different responses.
213 F.3d at 804. Even though Moersen did not also fulfill the role of music director, he nonetheless served, for all intents and purposes, as “the primary human vessel through whom the church chose to spread its message in song.” Id. The role of church organist almost certainly would be included at the epicenter of religious activity as described by Professor Bagni, whom the Fourth Circuit quoted in Rayburn in setting out the *677“primary duties” test.2 G. Sidney Buchanan, The Power of Government to Regulate Class Discrimination by Religious Entities: A Study in Conflicting Values, 43 Emory L.J. 1189, 1210 (1994) (discussing Bagni, supra, 79 Colum. L.Rev. at 1539).
Relatedly, I perceive that the Majority opinion makes too much of the leadership role and more extensive responsibilities of music directors and other ecclesiastical figures as contrasted to a “mere” organist in deciding whether either position is ministerial. As I have pointed out already, at least two federal appellate courts have noted that the manner in which religious music is played is, by itself, a matter of religious significance without regard to whether the performer selected that music. Further, the Diocese of Raleigh court opined that simply because an employee is answerable to a superior on spiritual matters, that fact does not de jure relegate that employee to any less of a religiously significant role; rather, it is just one factor to consider. 213 F.3d at 803. What is more important is whether the employee’s “primary duties consist of ... participation in religious ritual and worship.” Rayburn, 772 F.2d at 1169.
It is telling that the “primary duties” inquiry was dispositive in one of the cases relied upon by the Majority opinion and the Court of Special Appeals. In Assemany, George Assemany served as music director and organist for Gesu Parish in the Detroit area. In finding that Assemany’s position was ministerial, the Court of Appeals of Michigan held that he was “more than just an organist.” 434 N.W.2d at 238. The Majority opinion incorrectly seizes upon this language as proof positive that all church employees, including Moersen, who only play the organ, are not ministerial employees. To do so ignores the real test to be applied; the “primary duties” test, which was utilized in Assemany. In the paragraph preceding *678the “more than just an organist” language, the Assemany court found that the employee’s “primary responsibility was to enable and encourage the Gesu choir and congregation to participate in the Catholic liturgy through song.” 434 N.W.2d at 238. Surely, this same evaluation must be made of Moersen in his role as the organist at St. Catherine Labouré Parish. Although he alleges that he did not select the music to be played at liturgy, he nonetheless enabled and encouraged both the choir and the congregation to worship through music. Again, Moersen did not have to be in a position of leadership to impact the Parish’s liturgies through his exercise of his primary responsibilities. Diocese of Raleigh, 213 F.3d at 803.
For the reasons expressed above, I would hold that Moersen’s role was ministerial, thus placing his employment discrimination claim outside of our secular jurisdiction. Accordingly, the judgment of the Court of Special Appeals should be reversed and the matter remanded to that Court with directions to affirm the judgment of the Circuit Court for Prince George’s County.
Judges RAKER and CATHELL authorized me to state that they join the views expressed in this dissent.
. The Court of Special Appeals also accepted this and acknowledged that "music is generally an important part of the Catholic faith____”
. Rayburn v. Gen. Conf. of Seventh-Day Adventists, 772 F.2d 1164, 1169 (4th Cir.1985) (quoting Bruce N. Bagni, Discrimination in the Name of the Lord: A Critical Evaluation of Discrimination by Religious Organizations, 79 Colum. L.Rev. 1514, 1545 (1979)).