Court rules religious employers cannot hide behind First Amendment on wages

Ehrenkranz spent over two years at the Center, working in housekeeping, the kitchen, the garden, and even doing childcare for senior staff. In exchange, he received room, board, and a monthly stipend that started at $175 and peaked at $245. In November 2018, he left. In August 2020, he filed a wage claim, arguing he was owed proper minimum wages, overtime, and other compensation for the work he performed. 

The Labor Commissioner agreed and awarded him $81,170.23. The Zen Center appealed, and a trial court threw out his claims entirely, ruling that a First Amendment doctrine known as the ministerial exception barred them. That doctrine, first recognized by the U.S. Supreme Court in cases involving a church school teacher and Catholic school educators, was designed to protect religious organizations’ right to hire and fire their religious leaders without government interference. 

The problem, the appeals court found on March 2, is that the trial court stretched that doctrine too far. The ministerial exception was never meant to cover every employment dispute involving someone who qualifies as a minister. It was designed for cases where a court would have to wade into religious doctrine to resolve the dispute. Ehrenkranz’s claims – unpaid wages for cleaning guest bathrooms and chopping vegetables for paying visitors – required no such inquiry. 

The court noted that the Zen Center itself had acknowledged that resolving the wage dispute would not require any court to answer religious questions. That concession, the court said, was telling. 

The ruling aligns with a companion case, Lorenzo v. San Francisco Zen Center, decided last November, which reached the same conclusion on the ministerial exception. The two decisions did diverge on a separate procedural question, but on the core issue of whether the First Amendment shields religious employers from wage claims, both California courts landed in the same place. The California Supreme Court has since agreed to take up that broader legal question in the Lorenzo case, meaning the final word is still to come.