Church Autonomy Doctrine Requires Dismissal of Title VII Claim By Non-Ministerial Employee

Religion Clause ^ | 6/15/23 | Howard Friedman

[marshmallow]

In McMahon v. World Vision Inc., (WD WA, June 12, 2023), a Washington federal district court dismissed a Title VII sex discrimination suit, finding it is barred by the Church Autonomy Doctrine. A Christian ministry's job offer to plaintiff for the full-time position of Donor/Customer Service Representative Trainee was rescinded when defendant learned that plaintiff was in a same-sex marriage. The court discussed the relationship between the Church Autonomy Doctrine and the Ministerial Exception, concluding that the Church Autonomy Doctrine may be invoked when a non-ministerial employee brings a Title VII action. The court said in part:

... [T]he Church Autonomy Doctrine requires the court to abstain from resolving employment discrimination claims where a religious institution takes an adverse action pursuant to a religious belief or policy—regardless of whether the employer allegedly discriminated on religious or other protected grounds—unless it is possible for the court resolve the claims without resolving underlying controversies over religious doctrine or calling into question the reasonableness, validity, or truth of a religious doctrine or practice....

[Hebrews 11:6]

I've heard of the ministerial exception, but the "Church Autonomy Doctrine" is unfamiliar. Upon what is it based? First Amendment? Or a downstream Law or USSC ruling?

[circlecity]

I believe it states that the Church gets to decide what jobs are or are not ministerial and the court can’t second guess that based on the 1st amendment.

[Hebrews 11:6]

Thanks