Wednesday, August 06, 2025

9th Circuit: Ministerial Exception Requires Dismissal of Customer Service Representative's Title VII Suit

In McMahon v. World Vision, Inc., (9th Cir., Aug. 5, 2025), the U.S. 9th Circuit Court of Appeals held that the ministerial exception doctrine requires dismissal of a Title VII employment discrimination suit brought by a World Vision customer service representative ("CSR") whose job offer was revoked when the organization learned that he was in a same-sex marriage. World Vision is a Christian ministry which shares the gospel through outreach to poor and underserved children and families. The court said in part: 

We hold that the ministerial exception applies to a CSR not merely because they interface with the public, pray with their colleagues, or abide by World Vision’s requirements to embody Christian values.  Rather, CSRs qualify for the exception because (1) they are World Vision’s “voice,” responsible for “effectively communicat[ing] World Vision’s involvement in ministries and projects around the world”; (2) their engagement with donors is a form of ministry itself; and (3) they “give people an opportunity to join [World Vision] in the mission of God.”  Each of these religious responsibilities is “vital” to World Vision’s particular religious mission.