Ministerial Exception Barred Employee’s Discrimination Claims

Proskauer - California Employment Law
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Proskauer - California Employment Law

McMahon v. World Vision, Inc., 147 F.4th 959 (9th Cir. 2025)

World Vision, a religious organization, revoked a job offer it had made to Aubry McMahon to be a remote customer service representative after learning that McMahon was married to a same-sex partner. McMahon sued for discrimination based on sex, sexual orientation and marital status under Title VII and Washington state law. The district court initially granted summary judgment to World Vision based on the church autonomy doctrine before reversing itself and granting summary judgment in favor of McMahon. In this appeal, the Ninth Circuit reversed the district court, holding that the ministerial exception bars McMahon’s employment discrimination claims because World Vision’s customer service representatives perform key religious functions central to World Vision’s mission, including engaging with donors in prayer. Accordingly, the Ninth Circuit ordered the district court to grant World Vision’s motion for summary judgment. See also Petersen v. Snohomish Reg’l Fire & Rescue, 2025 WL 2503128 (9th Cir. 2025) (employer could not reasonably accommodate firefighters’ COVID-19 vaccine exemption requests without undue hardship).

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