Aubry McMahon, a practicing Christian in a same-sex marriage, applied for a remote customer service representative (CSR) position with World Vision, Inc., a Christian humanitarian nonprofit organization. Shortly after World Vision extended a written offer, McMahon emailed to inquire about parental leave, disclosing that she and her wife were expecting a child and that she would be giving birth. Days later, World Vision rescinded her job offer, citing McMahon’s inability to comply with its Standards of Conduct, which prohibit sexual conduct outside the Biblical covenant of marriage between one man and one woman.
McMahon filed suit under Title VII of the Civil Rights Act and the Washington Law Against Discrimination, asserting that World Vision had discriminated against her based on sex, sexual orientation, and marital status. The trial court initially granted summary judgment to World Vision under the church autonomy doctrine, which prohibits civil courts from interfering in issues that are fundamentally ecclesiastical. The trial court then reversed itself on reconsideration, holding that World Vision’s hiring policy was facially discriminatory, allowing the case to be resolved under neutral principles of law, without becoming entangled in religion. The trial court rejected World Vision’s constitutional and statutory defenses and entered summary judgment in favor of McMahon. The parties stipulated to $120,000 in damages.
On appeal, the Ninth Circuit reversed the reconsideration ruling, holding that the ministerial exception barred McMahon’s claims. The ministerial exception is a legal doctrine grounded in the First Amendment that prevents courts from interfering in employment disputes involving employees who perform key religious functions for a religious organization. Here, the Court emphasized that CSRs at World Vision are not typical administrative staff. The position required not only communication with donors and handling data entry, but also regular participation in prayer, attendance at weekly chapel and devotional sessions, and engagement in spiritual conversations with donors, including praying with and for them when appropriate. Training materials described the CSR as the “voice, face, and heart” of the ministry, and call recordings introduced at trial demonstrated that CSRs discussed World Vision’s mission, engaged donors in prayer, and helped deepen the donor’s connection to World Vision’s faith-based mission.
World Vision presented evidence that it views its donor engagement as a form of ministry and considers spiritual transformation of donors to be as central to its mission as the transformation of the vulnerable communities it serves. While the trial court had focused on the administrative aspects of the CSR position, such as call metrics and sales scripts, the Ninth Circuit concluded that the religious duties of the CSR role were not merely incidental. In fact, they were at the heart of the job’s purpose and directly advanced World Vision’s religious mission of bearing witness to Christ through service and partnership with donors.
The Court also rejected McMahon’s arguments that the religious aspects of the job were either shared across all employees or optional. The Ninth Circuit emphasized that shared religious expectations do not diminish the significance of those duties when assessing whether a particular role qualifies for the ministerial exception. Similarly, the Court explained that religious job functions need not dominate the role for the exception to apply—what matters is whether the religious functions are vital to the organization’s mission.
McMahon’s claims, based on sex, sexual orientation, and marital status, would ordinarily be cognizable under Bostock v. Clayton County, 590 U.S. 644 (2020), where the U.S. Supreme Court held that Title VII prohibits employment discrimination based on sexual orientation and gender identity. In Bostock, the Supreme Court reasoned that terminating an employee because of their same-sex relationship necessarily involves treating them differently “because of sex,” which Title VII forbids. However, the Ninth Circuit in McMahon did not reach the merits of that argument. Instead, it found that the First Amendment’s ministerial exception applied, and that this constitutional defense barred McMahon’s claims from proceeding. The Court emphasized that once the exception is triggered, it forecloses any inquiry into whether discrimination occurred, even under Bostock, because adjudicating the dispute would interfere with the religious organization’s right to select who performs vital religious functions.
The Court reversed the trial court’s judgment and remanded with instructions to enter summary judgment in favor of World Vision.
McMahon v. World Vision, Inc. (9th Cir. 2025) 2025 U.S. App. LEXIS 21345
Note: LCW covered this case previously. This case illustrates the limits of Bostock when applied to religious employers. While Bostock extended Title VII protections to LGBTQ+ individuals, the ministerial exception operates as a constitutional threshold defense that, when triggered, bars courts from reaching the merits of any discrimination claim, even one that would otherwise be viable under Bostock.