In Zan Sun v. Shen Yun Performing Arts, Inc., (SD NY, May 18, 2026), a New York federal district court held that the ministerial exception doctrine is not a basis for dismissing claims by two Falun Gong practitioners who allege that they were held in forced child labor by a classical Chinese dance and musical company based in New York. Plaintiffs allege that their treatment violated the Trafficking Victims Protection Reauthorization Act. The court said in part:
... Defendants argue that because Falun Gong is a “religion,” Dragon Springs is a “church,” Shen Yun is Falun Gong’s “evangelistic ministry,” and Plaintiffs were its “ministers” who used “performance art to share religious principles and the prospect of salvation with the world,” the ministerial exception bars all of Plaintiffs’ claims.... Plaintiffs counter that none of the Defendants are religious institutions and that Falun Gong is not a religion.... The Court, however, need not decide this dispute—even if it could on a motion to dismiss....
The ministerial exception “does not mean that religious institutions enjoy a general immunity from secular laws,”... Instead, the exception is limited: It “protect[s]” religious institutions’ “autonomy with respect to internal management decisions that are essential to [their] central mission.” ... A “church’s independence on matters ‘of faith and doctrine’ requires the authority to select, supervise, and if necessary, remove a minister without interference by secular authorities”....
Plaintiffs’ allegations of abuse, forced labor, and human trafficking do not implicate “matters of faith and doctrine” or “matters of internal government.” Plaintiffs claim they were subject to grueling training and work schedules with little pay, denied medical care when injured, prevented from leaving Dragon Springs, and subjected to other forms of psychological abuse that began when they were children. Accepting these allegations as true ... Defendants still retain the authority and independence to “select, supervise, and . . . remove [their] minister[s].” ... Matters of “faith,” religious “doctrine,” and ecclesiastical “government” have no bearing on alleged abuse, control, and confinement in between employment decisions....
... Defendants ... claim that, at most, what Plaintiffs allege they experienced is what one might expect at an elite dance academy or a boarding school.... [T]o the extent Defendants intend to prove that Plaintiffs were treated in the way they characterize, the resolution of this factual dispute does not implicate matters of faith and doctrine. It does not require interference with Defendants’ internal governance or even their right to choose ministers....
