Michael Ehrenkranz, a former Work Practice Apprentice (WPA) and staff member at the San Francisco Zen Center, filed wage-and-hour claims with the Labor Commissioner alleging unpaid minimum wages, overtime, split-shift premiums, liquidated damages, unreimbursed expenses, and waiting time penalties. The Zen Center is a nonprofit religious corporation operating three Zen Buddhist temples, including residential training programs. WPAs and staff live at the temples, participate in structured Zen practice schedules, and receive modest stipends along with room and board. Ehrenkranz’s duties included cleaning guest rooms, maintaining grounds, cooking for residents and paying guests, preparing meals during the Center’s commercial summer guest season, and later serving as a teacher’s assistant.
After a wage claim hearing before the California Labor Commissioner (often called a “Berman hearing”), the Commissioner ruled in Ehrenkranz’s favor and awarded him more than $81,000 in unpaid wages and penalties. The decision held both the Zen Center and two of its officers, Linda Galijan and Mike Smith, financially responsible. The Center and the individual officers appealed the decision to the superior court. Under California law, an employer appealing a Labor Commissioner award must post a bond equal to the amount awarded to ensure the employee can collect if they ultimately win; the Zen Center posted that bond, but the individual officers did not post separate bonds.
Defendants moved for summary judgment, arguing that Ehrenkranz’s claims were barred by the First Amendment’s ministerial exception. The trial court agreed and granted summary judgment, concluding that applying California wage-and-hour laws to WPAs would improperly entangle courts in religious governance. Ehrenkranz appealed.
The Court of Appeal reversed the summary judgment. Relying heavily on its companion decision in Lorenzo v. San Francisco Zen Center, which involved nearly identical facts and claims, the Court held that the ministerial exception does not categorically bar wage-and-hour claims simply because the plaintiff qualifies as a minister. Although Ehrenkranz conceded that he was a minister for purposes of the exception, the Court emphasized that the exception is limited to employment claims that necessarily require judicial inquiry into ecclesiastical decisions, such as hiring, firing, or selection of ministers. Here, Ehrenkranz sought only unpaid wages for work already performed, much of which related to the Center’s commercial activities. The Center conceded that adjudicating the wage claims would not require the court to resolve any ecclesiastical questions. Accordingly, absent evidence that applying wage laws would interfere with internal religious doctrine or governance, the ministerial exception did not apply.
The Court declined to follow Ninth Circuit authority broadly applying the ministerial exception to wage claims, reasoning that those cases provided limited analysis and extended the doctrine beyond the United States Supreme Court’s holdings in other ministerial exception cases. Instead, the Court adopted the reasoning of Lorenzo, concluding that the exception bars only those claims that intrude upon strictly ecclesiastical matters.
The Court of Appeal also addressed a separate issue about who had to post a bond in order to appeal the Labor Commissioner’s decision. Under California law, when an employer appeals a wage award, it must deposit a bond for the full amount of the award to protect the employee if the appeal fails. Ehrenkranz argued that because the two individual officers were held personally liable along with the Zen Center, they should have been required to post their own separate bonds. The Court disagreed, explaining that the statute requires only the employer to post the bond. Because the Zen Center, the actual employer, posted a bond covering the full award, the legal requirement was satisfied, and the individuals did not need to post separate bonds.
The Court of Appeal therefore reversed the summary judgment based on the ministerial exception but affirmed the denial of Ehrenkranz’s motion to dismiss the individual defendants’ appeals for failure to post separate bonds.
Ehrenkranz v. San Francisco Zen Center (Mar. 2, 2026) ___Cal.App.5th___ [2026 Cal. App. LEXIS 124].
Note: LCW previously issued a special bulletin on the Lorenzo decision. This decision clarifies that California courts will not automatically apply the ministerial exception to bar wage-and-hour claims brought by ministers. Religious schools should carefully evaluate whether compensation structures for their employees could give rise to wage-and-hour exposure.