California Court Rules Ministerial Exception Does Not Bar Wage and Hour Claim
A California appellate court has reversed a trial court judge’s grant of summary judgment in favor of a Zen Buddhist church in an employment law dispute. The appellate court rejected the trial court judge’s reasoning that the ministerial exception to employment law barred former employee Annette Lorenzo’s wage-and-hour claim. In his decision, Justice Danny Y. Chou also disregarded the U.S. Court of Appeals for the Ninth Circuit, which the Zen Center pointed to as persuasive authority. The case is Lorenzo v. San Francisco Zen Center, Cal. Ct. App. Nov. 21, 2025.
After the Labor Commission awarded Lorenzo almost $150,000 in back wages in her wage-and-hour claim, the Zen Center appealed. The trial court found a new trial unnecessary and granted the Zen Center’s motion for summary judgment, citing the religion clauses of the First Amendment. On further appeal, however, the appellate court judge found no evidence that Lorenzo’s claims raised ecclesiastical concerns, which led to its conclusion that the ministerial exception was inapplicable to her claims. As a result, the appellate court reversed the trial court’s decision and remanded the case to the trial court for further proceedings.
The U.S. Supreme Court first recognized the ministerial exception in Hosanna-Tabor Evangelical Lutheran Church and School v. EEOC, 565 U.S. 171 (2012). That case examined whether a terminated employee could sue his employer when the employer is a religious group, and the employee worked as a minister. The Supreme Court held that the ministerial exception barred the employee’s claim, as the church has the right to choose its ministers without government interference under the Establishment and Free Exercise clauses of the First Amendment.
Subsequently, in The Our Lady of Guadalupe School v. Morrissey-Berru, 591 U.S. ___, 140 S. Ct. 2049 (2020), the Supreme Court extended the ministerial exception to a Catholic school elementary teacher who had filed an age discrimination lawsuit against the school.
The Zen Center cited Alcazar v. Corp. of the Catholic Archbishop of Seattle, a 2010 case decided by the U.S. Court of Appeals for the Ninth Circuit, as persuasive authority for the proposition that the ministerial exception applies to minimum and overtime wage claims. However, Justice Chou flatly rejected the Zen Center’s argument, stating that Alcazar relied primarily on McClure v. Salvation Army, which, like Hosanna-Tabor and Our Lady of Guadalupe, concerned wrongful termination and employment discrimination claims, not wage-and-hour claims.
In contrast, Chou pointed out that Lorenzo was employed as a bathhouse attendant and kitchen helper at the Zen Center’s summer mountain resort as part of its Work Practice Apprentice program. Since Chou found no evidence that adjudication of Lorenzo’s claims would infringe on matters of “internal governance” protected by the religion clauses of the First Amendment, he found no reason to expand the ministerial exception to apply to all wage-and-hour claims.
Frequently Asked Questions (FAQ)
What is the difference between wage‑and‑hour claims and discrimination claims in the context of the ministerial exception?
Wage‑and‑hour claims typically involve disputes over pay, overtime, or working conditions. In contrast, discrimination claims focus on wrongful termination or unequal treatment based on protected categories like age or disability. The Supreme Court and other courts have generally applied the ministerial exception to discrimination cases involving religious roles, but whether it extends to all wage‑and‑hour disputes remains unsettled.
Why did the appellate court emphasize the employee’s specific job duties in Lorenzo v. San Francisco Zen Center?
The court looked closely at Lorenzo’s role as a bathhouse attendant and kitchen helper to determine whether her work was religious in nature. Because her duties were primarily secular and did not implicate the Zen Center’s internal governance or religious instruction, the court concluded that the ministerial exception did not apply.
How might this decision affect other religious organizations facing wage‑and‑hour claims?
The ruling suggests that California courts may limit the reach of the ministerial exception when employees perform primarily non‑religious tasks. Religious organizations should be prepared for wage‑and‑hour claims to proceed in civil courts unless the employee’s role is clearly tied to religious teaching or governance.
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