Wednesday, July 08, 2026

Church Autonomy Doctrine Prevents Review of Salvation Army's Ban on Certain Methadone Treatments in Its Rehab Centers

In Tassinari v. The Salvation Army, (D MA, July 6, 2026), a Massachusetts federal district court dismissed claims that The Salvation Army (TSA) violated the federal Rehabilitation Act and the Fair Housing Act when it denied plaintiffs residing in its Adult Rehabilitation Centers (ARCs) access to certain medications for their opioid use disorder. The Salvation Army disallowed treatment with methadone or buprenorphine because they are addictive narcotics, even though they have been approved by the FDA as Medications for Opioid Use Disorder (MOUD) and are not addictive when used in treatment. The court said in part:

TSA’s primary argument is that the church-autonomy doctrine shields its Medication Policy from government regulation and judicial scrutiny.... Specifically, TSA argues it is entitled to summary judgment because adjudication of this case involves matters of “faith and doctrine” that the First Amendment places beyond the ken of civil courts.... The undisputed facts establish that ARCs are residential churches with an evangelical mission in which Salvationist doctrine—including the prohibition on use of narcotics as MOUDs— determines the message TSA preaches and the rules by which beneficiaries must abide.  The relief the Injunction Class Plaintiffs seek would require the Court to evaluate and potentially invalidate TSA’s religious doctrine.  The First Amendment bars the Court’s interference in the challenged portions of TSA’s Medication Policy, and TSA is entitled to summary judgment....

TSA’s rehabilitation-through-conversion program requires beneficiaries to both engage in Salvationist practices—weekly chapel services and Bible studies, biweekly spiritual counseling, and daily devotions—and adhere to Salvationist rules—including the Medication Policy’s prohibition on use of narcotic MOUDs....  TSA sincerely believes, as a core tenet of Salvationist doctrine, that “abstinence and the power of God unto salvation” is the “only form of successful rehabilitation,” and that the long-term use of narcotics—including methadone and buprenorphine—to treat addiction is not true rehabilitation....