A California Court of Appeal has issued a significant decision that narrows when the ministerial exception precludes wage and hour claims under California law. The court held that these types of claims should not be automatically dismissed simply because the employee qualifies as a minister. Rather, a religious employer must also identify the religious rationale that would be affected by applying California’s wage and hour laws, such as one involving faith, mission, doctrine, or governance. This decision marks a meaningful departure from prior precedent.
What the Court Held
The ministerial exception is a First Amendment doctrine that protects religious organizations from government interference in matters related to their religious purpose. It also serves to avoid excessive entanglement between church and state.
Historically, courts, including the Ninth Circuit, typically treated ministerial status as sufficient to prevent wage and hour claims. Once an employee was deemed a minister, courts generally dismissed the claim without further inquiry.
The California Court of Appeal rejected that framework. The court held that even if an employee qualifies as a minister, the ministerial exception applies to wage and hour claims only when enforcement would affect a religious justification involving faith, mission, doctrine, or governance. Ministerial status alone is not enough. The employer must identify the religious rationale that would be impaired by enforcement of wage and hour laws, and this must involve a religious consideration rather than an administrative or organizational preference. The court explained that it was not adopting the broader federal precedent because those cases treated ministerial status as the end of the analysis rather than examining whether enforcement would interfere with religion.
Because this is a published Court of Appeal decision, it is binding statewide on all California state trial courts unless reversed by the California or U.S. Supreme Court. If another Court of Appeal issues a conflicting published decision, trial courts may choose which decision to follow until the conflict is resolved.
Impact for All Religious Organizations
Under this decision, religious organizations cannot rely solely on an employee’s ministerial status to prevent wage and hour claims. They will now need to be prepared to explain how enforcement of wage and hour laws would interfere with a religious basis involving faith, mission, doctrine, or governance when asserting the ministerial exception.
The ruling introduces a new legal requirement for asserting the ministerial exception in wage and hour matters. Religious organizations of all types, including congregations, schools, camps, and faith-based nonprofits, should review their classification practices and identify the religious rationale or justification that supports any assertion of the ministerial exception. Job descriptions should also be reviewed to ensure that employees intended to be classified as ministers satisfy applicable criteria, since ministerial status remains a threshold requirement. Failure to meet these requirements may increase wage and hour liability risk.
Conclusion
Although the holding in this case was limited to wage and hour claims, its reasoning may influence how courts evaluate the ministerial exception under other employment laws or policies. When a religious employer invokes the ministerial exception outside the wage and hour setting, courts may now require the employer to identify the religious justification that would be affected by enforcement of the particular law or policy. Given these potential implications, we encourage religious employers to consult with legal counsel to evaluate their potential exposure and identify options to reduce risk.
Our firm is available to assist with reviewing job descriptions, exempt classifications, and the religious rationales or justifications needed to meet this new legal standard.
Lorenzo v. San Francisco Zen Center (Cal. Ct. App. 2025) A171659