Released-Time Provider Sues School District After Termination For Facebook Posting

Suit was filed last week in a Georgia federal district court by a Christian ministry-- Sweet Onion Christian Learning Center-- that has offered released time off-campus religious instruction for students attending Vidalia, Georgia High School.  School officials canceled the released time program because of Facebook posts by Sweet Onion's executive director which criticized a proposed property tax increase for the city's schools. The complaint (full text) in Sweet Onion Christian Learning Center, Inc. v. Youmans, (SD GA, filed 5/8/2026), alleges that the cancellation violates the 1st and 14th Amendments as well as the Georgia Religious Freedom Restoration Act. The complaint reads in part:

2.... After learning about the posts, Superintendent Reid secretly investigated the Center and learned an unremarkable fact—the Center, a Christian ministry, provides Christian education. This led her to report to the Board that, in addition to the problems with the Facebook posts, Rev. Youmans’ instruction “reflected a particular interpretation of the Bible” that wasn’t presented in a “neutral or well-balanced manner.” Either way, Defendants punished Rev. Youman, his ministry, and the students at Vidalia High simply because Defendants disagreed with Rev. Youman’s constitutionally protected expression.  

3. Under the First Amendment, Rev. Youmans had a clearly established right both to criticize a proposed tax increase and to teach the Bible from his religious perspective. By punishing him and his ministry for his criticism and religious instruction, the Board and Superintendent Reid violated that right....

ADF issued a press release announcing the filing of the lawsuit.

President's Task Force on Anti-Christian Bias Issues Report

Yesterday, the President's Task Force to Eradicate anti-Christian Bias issued a report (full text) titled Eradicating Anti-Christian Bias within the Federal Government. The 197-page Report (with an additional 368 pages of Exhibits) focuses on policies of the Biden Administration, and concludes in part:

The Task Force found that, in its zealous pursuit of its preferred policies and constituents, the Biden Administration engaged in anti-Christian bias, seeking to limit Christians’ ability to act in concert with their sincerely held beliefs in their homes, in the workplace, and in the public square. At times, it went still further, leading Christians to reportedly choose between their beliefs and compliance with federal law. And, most troublingly, the Biden Administration is alleged to have prosecuted and jailed peaceful Christian pro-life demonstrators, terminated or harassed Christian workers who did not comply with the vaccine mandates, targeted Christian organizations with IRS inquiries, and subjected Christian schools to excessive fines. Taken together, the findings presented by the Task Force raise serious concerns about whether certain Biden-era policies and practices were administered in a manner consistent with the Constitution and applicable federal law. These concerns implicate core American commitments—religious liberty, equal treatment, and the rule of law—that protect all Americans of faith and conscience....

Our Nation’s forefathers recognized that our most essential rights are given to us by God and are not bestowed by civil government. By design, the Constitution and federal law limit the government’s reach into speech and religion to protect those inalienable rights from the vicissitudes of politics and changing times. Americans have been promised freedom of religion, not just in the privacy of their homes and four walls of their churches, but to daily walk in accordance with their religious teachings and conscience in the public square.

The National Catholic Register summarizes the Report.  The Freedom from Religion Foundation issued a press release strongly criticizing the Report.

T-Shirt Slogans Were Not the Exercise of Religion

In Spihes v. Smith, (D KS, April 29, 2026), a Kansas federal district court dismissed most of the claims brought by a Christian citizen journalist and activist challenging his removal from several demonstrations at the Kansas Capitol Statehouse grounds because of the slogans on shirts he was wearing. He also challenged a new policy on use of the Capitol grounds that has been promulgated by the Kansas Department of Administration.

The court dismissed plaintiff's claim that his removal from two events violated his rights under the Kansas Preservation of Religious Freedom Act. The court said in part:

The complaint alleges Plaintiff was wearing a t-shirt that said “Rolling with Jesus and my AK” to each of the events.... Further, at the March 28, 2025, event Plaintiff carried a sign that said, “Bet these pussies won’t blaspheme Islam next.”  ...  At the June 14, 2025, event, Plaintiff carried a sign that read “Illegals Drain American Resources” and “Deport Feminist Bitches First then Illegals.”...

Signs about immigration policy, much like signs about environmentalism, are not religious expressions.  Additionally, Plaintiff’s sign at the March 28, 2025, event, despite referencing Islam, is not religious exercise either, as it is merely a sign designed to score a political point about how society approaches a religion.  Plaintiff has not demonstrated that this is an exercise of his religion.  

Finally, Plaintiff’s shirt that states he is “Rolling with Jesus and [his] AK” is similarly just a statement about a religion, not the exercise of a religion....

The court also dismissed plaintiff's claim that the new policy on use of the Capitol grounds violates plaintiff's free exercise rights. The court said in part:

Plaintiff claims that the new Capitol Use Policy “requires Dr. Spiehs to impose no limitations or restrictions to participants in his permitted event based upon ‘sexual orientation, gender identity, or genetic information.’” ...  Plaintiff argues that this policy would force him to “use or employ people who are not his coreligionists: those who do not share, and who behave in ways antithetical to, his Christian beliefs and messaging.”... While Plaintiff does not object to having the “identified categories of individuals” present, he complains that the wording of the policy, specifically the use of the word “participate”, prevents him from limiting his usage of “vendors, staff, or volunteers” based upon their sexual orientation... Plaintiff explains that allowing “transgender, LGBTQ, or feminist” individuals to participate in his event would violate his religious convictions.....  

The law before the court is one that is neutral and generally applicable.  The post-July 1st Capitol Use Policy does not “facially target religion” nor is it “established for the purpose of targeting religion” and therefore does not trigger strict scrutiny....  The court does not view the word “participation”, as used in the policy, as imposing a requirement to hire individuals to whom Plaintiff has a religious objection.

The court allowed plaintiff to move ahead only on a 4th Amendment claim and a narrow free speech claim. 

White House Posts Presidential Message Marking 419th Anniversary of the Cape Henry Cross

Yesterday, the White House posted a "Presidential Message on the Anniversary of the First Landing and the Raising of the Cape Henry Cross" (full text). In it, the President says in part:

On this day 419 years ago, America’s birthright of faith was anchored in the sand when a courageous group of adventurers, explorers, and settlers planted a glorious wooden cross at the crest of Cape Henry, Virginia—a consecration of the new frontier that laid the foundation for the greatest Republic in the history of the world.  Today, our Nation pays tribute to the heroes who landed at Cape Henry in the spring of 1607, and we pledge to pioneer a future that once again upholds our traditions, cherishes our values, and places our trust in Almighty God.

On April 26, 1607, 104 men completed a daring voyage across the Atlantic in search of opportunity in the Americas.  Commissioned by King James I and the Virginia Company of London, they were guided by a noble mission:  to extend Christendom’s dominion in the New World, secure their prosperity, and spread the Gospel of Jesus Christ....

British Court Reverses Conviction of Christian for Sending Offensive Anti- Abortion Emails

In The King v. Skinner, (Crown Ct., April 24, 2026), a British Crown Court set aside a Magistrate Court's conviction under the Communications Act. Defendant was convicted of violating a provision of the Communications Act that prohibits sending "grossly offensive" messages by means of a public electronic communications network. Defendant, a Christian anti-abortion advocate, sent e-mails captioned "Reporting Mass Murder..." to two police officials. The emails contained pictures of aborted fetuses and made comments about "brutal killings". The emails also contained pictures of Nazi concentration camp victims. The court said in part:

First, the views expressed in the Letters (as supported by the Images) are political speech entitled to the highest form of protection. The abortion debate raises important matters of public interest where strong views are legitimately held and expressed, often in forceful terms, by persons on each side of the argument. ...

Second, an individual has the right to use images as a form of speech in a way which will shock and offend and indeed it is of often the power of an image which carries the message in its strongest terms....

Third, the intended recipients of the Letters were public officials....

In summary, the Crown has not satisfied us under the demanding standard applied to restrictions on political speech, that the conviction is a justifiable interference with Mr. Skinner’s Article 10(1) rights. On the facts, that restriction has not been demonstrated to be necessary in our modern democratic society

Law & Religion UK reports on the decision.

Plaintiff Lacks Standing to Challenge Creation of Taks Force to Eradicate Anti-Christian Bias

In Hall v U.S. Department of Justice, (ND CA, April 9, 2026), a California federal district court held that plaintiff lacks standing to challenge on Establishment Clause grounds the Justice Department's use of Congressionally appropriated funds to create the Task Force to Eradicate Anti-Christian Bias. Concluding that plaintiff lacks taxpayer standing, the court said in part:

If a plaintiff cannot show that the challenged action “was expressly authorized or mandated by any specific congressional enactment,” then that plaintiff’s lawsuit “is not directed at an exercise of congressional power, and . . . lacks the requisite logical nexus between taxpayer status and the type of legislative enactment attacked.”...

... [A]s alleged in his FAC, Hall is challenging allegedly unauthorized actions by the DOJ. He thus cannot show that those challenged actions were “expressly authorized or mandated by any specific congressional enactment.”

Defense Secretary's Wartime Prayer Services Draw Criticism

Last week, Americans United for Separation of Church and State filed a Freedom of Information Act lawsuit against the Defense Department seeking information about Secretary of Defense Pete Hegseth's monthly Christian Prayer & Worship Services at the Pentagon. (Full text of complaint in Americans United for Separation of Church and State v. U.S. Department of Defense, (D DC, filed 3/23/2026)). Military Times last week reported on the religious services in an article titled Hegseth Prays for 'Overwhelming Violence' During Pentagon Christian Service. Pope Leo XIV's Palm Sunday Homily seemed to aim criticism at Hegseth. The Pope said in part:

Brothers and sisters, this is our God: Jesus, King of Peace, who rejects war, whom no one can use to justify war. He does not listen to the prayers of those who wage war, but rejects them, saying: “Even though you make many prayers, I will not listen: your hands are full of blood” (Is 1:15).

3rd Circuit: Prison Officials Have Qualified Immunity in Inmate's Lawsuit Over Right to Receive Religious Pamphlets

In Cordero v. Kelley, (3rd Cir., March 19, 2026), the U.S. 3rd Circuit Court of Appeals held that prison officials who refused to allow an inmate to receive a bulk mailing of religious pamphlets had qualified immunity in a damage action against them alleging violation of the 1st Amendment. The court said in part:

Cordero asserts that his Christian religion requires him to spread the Word of God by sending religious pamphlets, or tracts, to friends and family.  Prior to 2015, Cordero was able to receive hundreds of pamphlets at a time via mail at NJSP without incident.  However, from 2015 to 2017, Gregory Kelley, a correctional officer working in the NJSP mailroom, rejected multiple bulk mailings containing 100 or more religious pamphlets....

We agree with the District Court that the defendants were entitled to qualified immunity on Cordero’s First Amendment claim for damages.  We have found no caselaw clearly establishing a right to either receive through the mail bulk quantities of religious materials, or the right to receive a yearly bulk order of Christian tracts....

Cordero also argues that the New Jersey Administrative Code mandates that he “be permitted to receive, retain and send out religious literature without quantity limitations.”... However, “[o]fficials sued for constitutional violations do not lose their qualified immunity merely because their conduct violates some statutory or administrative provision.”  Davis v. Scherer, 468 U.S. 183, 194 (1984).  Rather, the “clearly established right must be the federal right on which the claim for relief is based.”  Doe v. Delie, 257 F.3d 309, 319 (3d Cir. 2001).  And a “state statute cannot ‘clearly establish’ the federal right for qualified immunity purposes.”  Id.  

High School Teacher Did Not Violate Constitution in Counseling Muslim Student Who Converted to Christianity

In Chaudhry v. Thorsen, (ND IL, March 18, 2026), an Illinois federal district court rejected Establishment Clause, substantive due process, and equal protection claims against Pierre Thorsen, a high school history teacher, brought by Muslim parents of one of Thorsen's students. According to the court:

Entering Jacobs High School, Aliya—the daughter of Chaudhry and Alvi—identified as Muslim but was actively questioning her faith. In two classes with Thorsen, she established a strong rapport with him. She trusted him enough to approach him and ask personal questions related to her faith, having conversations before and after school....  As Aliya gradually chose to convert from Islam to Christianity, Thorsen grew concerned for her well-being given the ongoing family dynamics that she professed to him. He connected her to resources in the community, some of which included his own personal connections: a neighbor, a pastor, and former students. He also, at her request, gave her a Bible from one of these connections.....

Parents suffer no legal injury when their child uses his or her own free will and independent judgment to embrace beliefs that differ from their own.... 

Thorsen’s actions weren’t coercive. He never forced Aliya to talk to him. Rather, she initiated their conversations. When they talked, he didn’t badger Aliya into changing her beliefs. Instead, he talked with her about his own beliefs while also encouraging her to speak to her parents and an imam when she expressed doubts about her religion. It may not have been appropriate for Thorsen to ... connect her with adults in the community, particularly without at least looping in Jacobs’ administration or social workers, if not Aliya’s parents. But this doesn’t violate the Constitution, because Aliya wasn’t coerced into religious activity. Inappropriateness doesn’t necessarily violate the Constitution....

Distinguishing between “historical” teachings consistent with what every high school history student should know and “theological” lessons better reserved for Sunday School is a difficult line to draw, but, wherever it is drawn, Thorsen didn’t cross it. 

As a matter of law, Thorsen’s actions didn’t impermissibly establish religion in violation of the Establishment Clause....

The leap required to get from his actions—assisting Aliya in a pre-existing religious journey—to a nefarious discriminatory intent against Muslims as a class, is far beyond the capabilities of a reasonable jury, and the Court can’t allow the claim to proceed as a matter of law.

County Employee Sues Over Denial of Religious Accommodation So He Could Avoid Celebrating Pride Month

Suit was filed yesterday in a California federal district court by an employee of the Los Angeles County Department of Public Works alleging that the county violated Title VII as well as the 1st and 14th Amendments and California law by denying him a religious accommodation so he would not have to celebrate Pride Month. The complaint (full text) in Batman v. Los Angeles County, (CD CA, filed 3/10/2026), alleges in part:

4. Beginning in March 2023, the County directed all of its government departments to ensure that the “Pride Progress Flag” was flown at every government department.... The policy revisions also directed the government offices to adopt ways to demonstrate that all government offices celebrate so-called “Pride Month” and make its celebration overt, express, and universal.  

5. As a result of his sincerely held religious beliefs and a conflict with his employer’s open and notorious celebration of something Batman considers a sin, Batman requested a simple accommodation of working remotely during the one month of the year that his employment requirements conflict with his sincerely held religious beliefs.....

82. Rather than provide Batman a reasonable accommodation that was plainly available and not burdensome to anyone, Batman was instructed that he could simply use the back entrance....  

83. The Department also suggested to Batman that he seek mental health counseling for any distress he may feel as a result of the conflict between his sincerely held religious beliefs and the Department’s denial of his requested accommodation.... In other words, the Department suggested to Batman that his religious beliefs required mental health counseling rather than accommodation.

The complaint sets out at length the Biblical basis for plaintiff's beliefs.

Liberty Counsel issued a press release announcing the filing of the lawsuit.

Advocacy Group Says Military Commanders Are Describing Iran Operations in Christian Biblical Terms

The Military Religious Freedom Foundation, an advocacy organization dedicated to assuring church-state separation in the armed forces, reported yesterday that it has received numerous complaints from military personnel that, in briefings, their commanders are describing the military operations against Iran in Christian eschatological terms. According to a report on Substack by journalist Jonathan Larsen:

A combat-unit commander told non-commissioned officers at a briefing Monday that the Iran war is part of God’s plan and that Pres. Donald Trump was “anointed by Jesus to light the signal fire in Iran to cause Armageddon and mark his return to Earth,” according to a complaint by a non-commissioned officer.

From Saturday morning through Monday night, more than 110 similar complaints about commanders in every branch of the military had been logged by the Military Religious Freedom Foundation (MRFF).

The complaints came from more than 40 different units spread across at least 30 military installations, the MRFF told me Monday night.

President Trump's Ash Wednesday Message

Yesterday, the White House posted a Presidential Message on Ash Wednesday (full text). It reads in part:

Today, the First Lady and I join the millions of Christians in the United States and around the world in observing Ash Wednesday—a solemn day of prayer and repentance and the beginning of the Lenten season.

Every Ash Wednesday, Christians receive ashes in the shape of a cross on their foreheads as a visible reminder of our belonging to Jesus Christ and our enduring need for penance....

... [W] are reminded that the practices of prayer, fasting, and almsgiving have been foundational to our strength from the earliest days of our national story.  From the Colonists who turned to prayer and fasting in the heart of the Revolutionary War to the unmatched compassion and generosity of America’s churches, hospitals, and charitable institutions, these righteous acts of faith over the centuries have always stood at the center of our identity, our heritage, and our way of life....

Above all, as we prepare for the triumphant resurrection of Jesus Christ on Easter Sunday—the greatest miracle in the history of mankind—we pause to remember those sacred words:  “This is the time of fulfillment.  The Kingdom of God is at hand.  Repent, and believe in the Gospel.”

Palestinian Authority Unveils New Draft Constitution

Times of Israel reported earlier this month:

Palestinian Authority President Mahmoud Abbas received a draft constitution [on February 5] ... that aims to transition the PA to a full-fledged state, Ramallah’s official Wafa media outlet said....

Abbas ordered that the draft constitution be submitted to the Palestine Liberation Organization’s Executive Committee for review before being made available for public feedback, a process that could take months to over a year, a Palestinian official told The Times of Israel.

It will then have to go through a public referendum and receive a majority support in order to come into effect.

The "Draft of the Temporary Constitution of the State of Palestine" (full text) contains a number of provisions on religion and religious freedom. It provides in part:

Preamble: ... Palestine is the cradle of heavenly religions, where peace was preached and where the Messenger of God travelled; it is the land of prophets, the meeting place of religions, and the cradle of civilizations.  From its heart, this constitution draws the essence of humanity, where faith is a guide, tolerance is a lifestyle, and justice and peace are a goal for those who seek it....

Article 3, Sec. 2:  The state is committed to preserving its religious character and protecting its Islamic and Christian sanctities, as well as its legal, political, and historical status....

 Article 4, Sec. 1: Islam is the official religion in the State of Palestine.  

Sec. 2: The principles of Islamic Sharia are a primary source for legislation.  

Sec. 3: Christianity has its status in Palestine, and its followers' rights are respected.

 Article 37: Freedom of belief is absolute, and the freedom to practice religious rites and establish places of worship for followers of monotheistic religions is a right regulated by law. ...

Article 38 Sec. 3: The law prohibits any call for racial or religious hatred that constitutes incitement to discrimination, hostility, or violence.

Article 69 Sec. 1: The law punishes the crimes of genocide, crimes against humanity, war crimes, aggression, and all serious and systematic violations of human rights. They are not subject to a statute of limitations and may not be pardoned.

 Article 132 Sec. 1: Sharia disputes and personal status are handled by Sharia and religious courts.

Fellowship of Christian Athletes Can Move Ahead Against School Officials on Two Counts

In Fellowship of Christian Athletes v. District of Columbia, (D DC, Feb. 3, 2026), the D.C. federal district court found that Fellowship of Christian Athletes' (FCA) claims against D.C. public schools and two school officials were not moot even though the school system revised its rules to allowed religious student organizations to give preference to members of the organization's religious affiliation. The school had originally revoked recognition of FCA because FCA required that students serving in a leadership capacity subscribe to a Statement of Faith and a policy of sexual purity. The court held that the individual defendants had qualified immunity as to FCA's various 1st Amendment claims, to their claims under RFRA, the Equal Access Act and the Equal Protection Clause. The court said, however:

Chancellor Ferebee and CIO Ruiz are not entitled to qualified immunity as to Counts VI and VII.  FCA alleges that the defendants selectively enforced DCPS’s Anti-Discrimination Policy on the basis of viewpoint (Count VI) and that enforcement of the policy against FCA violated FCA’s First Amendment right to expressive association (Count VII)....

In light of this Supreme Court and circuit case law, the Court concludes that the law was “sufficiently clear” that a “reasonable official” would have known that the challenged actions violated FCA’s First Amendment free speech and expressive association rights....

Organization Releases 2026 Report on Christian Persecution Worldwide

Last week, the Christian advocacy organization Open Doors released its report World Watch List 2026 which assesses the persecution of Christians around the world. The report covers the period from October 1, 2024, to September 30, 2025 (methodology). The Report focuses on the 50 countries where persecution of Christians is highest. North Korea leads the list. Zeale reports on the data.

Anti-Abortion Sidewalk Counselor Loses Challenge to City's Sign Ordinance

In Hamann v. City of Carbondale, Illinois, (SD IL, Jan. 21, 2026), an Illinois federal district court refused to preliminarily enjoin the city of Carbondale's sign ordinance. The Ordinance prohibits plaintiff, a Christian minister, from temporarily placing his anti-abortion signs in the ground on public property near an abortion clinic while he is attempting to persuade women not to have an abortion. Under the Ordinance, he can carry or wear the signs but cannot place them into the ground. The court rejected plaintiff's claims that the Ordinance is unconstitutionally vague and violates his free speech rights. It concluded that the Ordinance is a permissible time, place and manner regulation of speech in a public forum. The court went on in part:

Hamman’s final argument advances a theory of viewpoint discrimination based on the City’s “policy of inaction” towards signs that share messages other than his.... He submitted photos of three temporary signs he found throughout Carbondale which, he believes, were placed in the public right of way and not removed the way his were. From there, he contends that the City engaged in a “targeted campaign of enforcement” against his signs based on their anti-abortion messages....

Hamman acknowledges that he does not know how long these signs had been in the public right of way when he photographed them. This, then, leaves open the possibility that the City had not had time to remove them—something that, Lenzini explained, can happen from time to time. Surely, if these signs had been placed in the public right of way with the City’s permission, or been left there after the City became aware of them, such evidence would support Hamman’s claim of selective enforcement. But the record reveals no such evidence....

Samoa's Prime Minister Suggests Restricting Religious Liberty for Non-Christians

 Australian Broadcasting Corp. reported this week that in the Southern Pacific island nation of Samoa, with a population of 220,000, religious liberty is being threatened. According to ABC's report:

... [T]he country's prime minister has thrown the future of its religious minorities into doubt after flagging potential restrictions on non-Christian faiths last month.

Laaulialemalietoa Polataivao Fosi Schmidt said he wanted to stop Samoa encountering the same religious divisions as "neighbouring countries", and in the Middle East.

"It may not be happening now, but there will come a time when a large number could gather under a non-Christian religion in Samoa. Then we will face what we do not wish to see," he said....

Laaulialemalietoa has asked the nation's peak Christian body, the Samoa Council of Churches, to advise him on the country's religious freedom laws....

"I am prepared to take the necessary actions on what Samoa decides — perhaps through a referendum or national discussion — to consider amending the constitution regarding the freedom of religion," he said.

The prime minister, who has gained a loyal voting base with his devout Christian public persona, is moving quickly to stamp his religious agenda on other parts of Samoan society since his August election victory.

His government has made weekly fasting and prayer mandatory for public servants. ...

And as the prime minister raised the potential restrictions on non-Christian faiths last month, he announced a ban on construction work on Sundays....

Street Preachers' Challenges to Noise Ordinance Fail

 In Cabral v. City of Fort Myers, Florida, (MD FL, Jan. 6,2026), a Florida federal district court dismissed a First Amendment challenge to Fort Myers' Noise Ordinance brought by three Christian street preachers. The challengers were cited for violating the Ordinance's ban on drivers, passengers or pedestrians producing amplified sound that can be heard over 25 feet away. The court rejected plaintiffs' facial and their as-applied challenge to the Ordinance, saying in part:

You don’t get to strike down a city’s noise-control policy just because it might catch a few conversational speakers in its net; you have to show that the net is designed so poorly that it catches a substantial amount of protected speech....

An as-applied challenge against the City ... requires a showing that the City itself—not just an officer with a badge and a misunderstanding of the word “pedestrian”—has a policy of targeting speech it doesn’t like. But Plaintiffs don’t seem to make such a claim. Instead, they allege the Ordinance was inapplicable to them. Even if true, such facts don’t alone trigger the First Amendment....

Though styled as an as-applied challenge under the First Amendment, Plaintiffs’ free exercise claim reads as a Fourteenth Amendment selective enforcement claim....

Plaintiffs claim that the Ordinance was enforced against them while other individuals were making amplified noise audible from 25 feet away.... But Plaintiffs don’t allege that these other individuals weren’t also cited for violating the Ordinance. Nor are these other individuals alleged to have been producing sound on public property. Without those specific facts, the allegation of targeting is just a hunch, not a plausible legal claim.

9th Circuit: Church Autonomy Doctrine Allows Churches to Hire Only Co-Religionists Even for Non-Ministerial Positions

In Union Gospel Mission of Yakima, Washington v. Brown, (9th Cir., Jan. 6, 2026), the U.S. 9th Circuit Court of Appeals upheld a preliminary injunction barring enforcement of Washington's Law Against Discrimination against a Christian ministry that gives hiring preference to co-religionists for non-ministerial positions. The court said in part:

The freedom of religious institutions to establish their own doctrine and faith is so fundamental that they may categorically hire and fire their ministers without regard to anti-discrimination laws—even if the termination is for non-religious reasons.  Simply, the government has no business in policing who spreads the word on behalf of churches, synagogues, mosques, religious organizations, and other similar institutions.  

But the church autonomy doctrine is not so narrowly drawn.  The First Amendment may also shield religious institutions’ hiring of non-ministerial employees when it involves matters of faith and doctrine.  For example, a religious institution may decide that its religious mission is best served by hiring only employees who adhere to and follow its religious beliefs—even for those not acting in ministerial roles. The religious institution may also believe that it can more effectively promote its view of moral and spiritual well-being if its own employees do not lead lives contrary to the institution’s teachings....

But unlike with the ministerial exception, the church autonomy doctrine only protects Union Gospel’s non-ministerial hiring decisions based on religious beliefs.  So Union Gospel cannot discriminate on any other ground.  And our decision is limited to religious organizations like Union Gospel.  We do not consider the scope of the doctrine on other types of entities run by religious institutions, such as businesses or hospitals....

Yakima Herald Republic reports on the decision. 

Lower Court Applies Supreme Court's Classroom Religious Opt-Out Decision

In Alan L. v. Lexington Public Schools, (D MA, Dec. 30, 2025), a Massachusetts federal district court, relying on the Supreme Court's recent decision in Mahmoud v. Taylor, held that the father of a 5-year-old kindergartener has the right to opt his child out of classroom lessons and activities that deal with sexual orientation and gender identity and violate plaintiff's Christian religious beliefs. Plaintiff identified ten books of concern. The court's injunction (full text) provides in part:

3. Defendants shall make reasonable efforts to ensure that J.L. is not taught or otherwise exposed to the content of the Identified Books, whether in the classroom or any other school setting. 

4. By January 20, 2025, defendants shall provide plaintiff with copies of any Other LGBTQ+ Educational Materials in their possession. 

5. By January 27, 2025, plaintiff shall specifically identify in writing any Other LGBTQ+ Educational Materials that he contends would burden his free-exercise rights by “substantially interfer[ing] with” J.L.’s “religious development” or posing a “very real threat of undermining the religious beliefs and practices” he wishes to instill in J.L.   

6. After receipt of plaintiff’s written response, defendants shall make reasonable efforts to ensure that J.L. is not taught or otherwise exposed to all Other LGBTQ+ Educational Materials identified by plaintiff, whether in the classroom or any other school setting....

9. Defendants shall make reasonable efforts to ensure that J.L. is able to receive reasonable and age-appropriate alternative instruction during any time he is removed from his classroom or any school assembly or activity in order to comply with this order.....