In Ehrenkranz v. San Francisco Zen Center, (CA App, March 2,2026), a California state appellate court held that the trial court erred in applying the ministerial exception doctrine to the wage-and-hour claims brought against a Zen Center by one of its Work Practice Apprentices. The court said in part:
Ehrenkranz contends that the trial court erred in applying the ministerial exception to bar his wage-and-hour claims because the United States Supreme Court has only applied the exception to bar a minister’s employment discrimination and wrongful termination claims and his wage claims do “not implicate [the Center’s] ability to hire or fire its ministers.” He claims his case is instead about unpaid minimum wages and does not concern any ecclesiastical matter. ...
[B]arring a minister’s employment claim without any evidence that the claim would raise an ecclesiastical concern is necessary to comply with the First Amendment only if that claim will inevitably ‘thrust the secular courts into the constitutionally untenable position of passing judgment on questions of religious faith or doctrine.’ ... Thus, the ministerial exception only bars employment claims that require inquiries into matters that are ‘ “ strictly a matter of ecclesiastical government’ ” ...
... We therefore conclude that the ministerial exception does not apply to Ehrenkranz’s claims in the absence of evidence of an ecclesiastical concern....
In sum and in short, the trial court erred in granting summary judgment to defendants. However, “our ruling here today does not foreclose the Center from presenting evidence at trial that applying wage-and-hour laws to ministers like [Ehrenkranz] raises an ecclesiastical concern and should therefore be barred under the Religion Clauses.”