In Lorenzo v. San Francisco Zen Center, (CA App., Nov. 21, 2025), a California state appellate court held that neither the ministerial exception doctrine nor the church autonomy doctrine bars a wage-and-hour claim for past services by an employee who is a "minister" under the ministerial exception doctrine. The court held that the ministerial exception doctrine does not apply because plaintiff's wage claims do not raise an ecclesiastical concern. The court said in part:
... Lorenzo only challenges the Center’s failure to pay her a minimum wage and overtime wages for work that she has already performed as part of the Center’s commercial activities. She does not challenge the Center’s decision to terminate her employment or seek reinstatement. Despite this, the Center asserts that the enforcement of California’s wage-and-hour laws would inevitably result in excessive entanglement with religion in violation of the Religion Clauses solely because Lorenzo is a minister. But the Center does not explain why, and its omission is telling. ...
“[T]he aspect of the church-minister employment relationship that warrants heightened constitutional protection—a church’s freedom to choose its representatives”—is not “present” in every employment claim.... For example, not every aspect of a minister’s compensation is “an internal church decision that affects the faith and mission of the church itself.”... Indeed, “[t]he constitutional rationale for protecting some of a church’s [autonomy to choose its representatives] . . . does not apply . . . where what is at issue is not who the [church] will select to educate its youngest students, but only whether it will provide the people it has chosen with meal breaks, rest breaks, and overtime pay.”...
...[T]he Center has not pointed to and we have not come across anything in the history of the Religion Clauses to suggest that a minister’s compensation, much less the minimum compensation that a minister should receive to subsist, was a concern of the founders....
