Labor & Employment Law Daily Wrap Up, COVERAGE, LIABILITY—9th Cir.: Ministerial exception applies to Christian organization that rescinded job offer after discovering same-sex marriage, (Aug 6, 2025)

By Todd Harrison, J.D.

The exception applied to a customer service representative role not merely because they were required to embody Christian values, but because their responsibilities were “vital” to the organization’s religious mission.

Reversing a district court’s grant of summary judgment in favor of a job applicant who alleged discrimination based on sex, sexual orientation, and marital status under Title VII and the Washington Law Against Discrimination (WLAD), the Ninth Circuit determined that the ministerial exception barred the applicant’s employment discrimination claims because her role as a customer service representative required her to perform key religious functions central to the putative employer’s mission. The district court, upon reconsideration, decided that because the organization had acted under a “facially discriminatory hiring policy” it could resolve the case under “neutral principles of law” without becoming entangled in religion. Given the vital role customer service representatives play in the organization’s mission, the district court erred in disallowing the ministerial exception defense (McMahon v. World Vision Inc., No. 24-3259 (9th Cir. Aug. 5, 2025)).

World Vision describes itself as a “Christian ministry dedicated to sharing the gospel of Jesus Christ” through “humanitarian outreach to children and families around the world who are poor and underserved.” World Vision pursues this mission through partnership with donors, prayer supporters, and churches.

Values. Every World Vision employee is provided with an employee guidebook which instructs that prayer “plays a central role in World Vision’s ministry.” Each World Vision team is expected to spend one hour each week in team devotions, and all employees are “invited and expected” to attend a weekly “organization-wide chapel” service.

In addition, World Vision provides standards of conduct to clarify its expectations of employees, including its belief that the Bible confines marriage solely to “a faithful marriage between a man and woman.” To be eligible for employment at World Vision, an individual must be able and willing to affirm and comply with these standards.

Customer service role. The plaintiff in this case, an openly gay Christian woman in a same-sex marriage, applied for a customer service representative role with World Vision. The position did not require any formal religious education or training, and the job posting primarily listed secular responsibilities, including experience in a customer service role and the ability to multi-task.

A more detailed job description further defined the role, which again largely consisted of secular responsibilities, but also mentioned that customer service representatives were expected to learn and effectively communicate World Vision’s involvement in ministries and projects around the world, and to be sensitive to donor’s needs and to pray with them when appropriate.

In addition, customer service representatives fall under World Vision’s Donor Contact Services (DCS) department. DCS describes its employees as “the Voice, Face and Heart of World Vision” because they “interact all day with the ministry’s donors, its lifeblood.”

Job offer. Shortly after applying for a customer service representative role, the applicant underwent a phone interview. When asked if she was willing to comply with World Vision’s standards of conduct, she stated, “I’m aligned, yes!”

Following the interview, World Vision extended a formal offer of employment. That same day, the applicant sent an email informing World Vision that she and her wife were expecting a child and inquired whether she would be entitled to any time off after she was expected to give birth in two months. After receiving this email, World Vision decided to rescind the job offer because of the applicant’s “inability” to comply with the standards of conduct prohibiting sexual conduct outside the Biblical covenant of marriage between a man and a woman.

Lawsuit. Subsequently, the applicant filed this lawsuit. The district court initially granted summary judgment to World Vision under the church autonomy doctrine. The applicant successfully moved for reconsideration, arguing that World Vision had acted under a “facially discriminatory hiring policy” and the court could resolve the case under “neutral principles of law” without becoming entangled in religion. Upon reconsideration, the court reversed its initial decision, granting summary judgment in favor of the applicant. In lieu of a jury trail on damages, the parties stipulated to a settlement of $120,000.

Facially discriminatory. On appeal, the Ninth Circuit agreed with the district court’s determination that World Vision’s Biblical marriage standards of conduct were facially discriminatory and it was liable under Title VII and the WLAD unless it could establish an exemption or defense, including by showing that the customer service representative position qualified for the ministerial exception.

Administrative or ministerial? According to the district court, the customer service representative position was secular and lacked ministerial or religious substance given that representatives do not receive significant doctrinal instruction or a religious commissioning, are not required to perform any unique important religious functions, and perform primarily secular job responsibilities.

Although the district court considered the fact that they may engage in donor prayer in World Vision’s favor, it ultimately concluded that a customer service representative’s job duties—answering calls, up-selling, data entry, sales work, typing proficiency—“demonstrate[d] that the thrust of the customer service representative position is administrative, not ministerial.” The court here disagreed with that conclusion.

“Vital religious duties.” When viewing the religious functions of customer service representatives within the context of World Vision’s mission, the appellate court found that the role qualified for the ministerial exception because customer service representatives perform “vital religious duties” which lie at the heart of World Vision’s mission, and the district court erred by viewing the responsibilities of customer service representatives in the abstract, isolated from World Vision’s central mission.

World Vision describes its customer service representatives as its “lifeblood” because they are the sole employees interfacing with donors and soliciting donations, which World Vision views as a form of ministry or religious practice, explained the court. Further, customer service representatives minister to donors through prayer. In this way, World Vision considers customer service representatives to be its “voice.”

Without its customer service representatives, “World Vision would be severely hindered in pursuing its central religious mission,” said the court.

Secular job duties. According to the applicant, the duties of the customer service representative position are overwhelmingly secular, and the ministerial exception should not apply. The court was not persuaded, explaining that “The Supreme Court has imposed no requirement that the “thrust” of the position be ministerial, or that a particular quantum of the position’s job duties be religious in nature.”

Equally applicable duties. The court also rejected the applicant’s argument and the district court’s conclusion that religious job duties that are equally applicable to all World Vision employees carry diminished or no relevance in the ministerial exception analysis. The district court did not cite any authority for the proposition that a position is less likely to be central to a religious organization’s core mission if its religious duties are shared with general members of that organization, explained the appellate court.

Here, while the obligations of customer service representatives to attend chapel and to bear witness to Jesus Christ are shared by all World Vision employees, customer service representatives also occupy a unique role in that they “give people an opportunity to join [World Vision] in the mission of God” through monetary donations underwriting the organization’s mission.

Secretaries, accountants, and custodians of World Vision, despite having the same religious obligations to attend chapel and bear witness to Jesus Christ, would not qualify for the ministerial exception because, unlike customer service representatives, they are not charged with conveying the organization’s message to its donors—a role “vital” to World Vision’s central mission, concluded the court.

Because World Vision carried its burden of showing that there was no genuine issue of material fact as to whether a customer service representative qualifies for the ministerial exception, it was entitled to summary judgment. The judgment of the district court was reversed and remanded for entry of summary judgment in favor of World Vision.

The case is No. 24-3259.

Judge: Tallman, R.

Attorneys: Michael Craig Subit (Frank Freed Subit & Thomas) for Aubry McMahon. Scott J. Ward (Gammon & Grange) for World Vision Inc.

Companies: World Vision Inc.

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