Recent California appellate decisions are reshaping how religious organizations may need to think about wage and hour exposure. Two published opinions—Lorenzo v. San Francisco Zen Center and Ehrenkranz v. San Francisco Zen Center—suggest that the First Amendment’s ministerial exception does not provide blanket immunity from minimum wage and overtime claims simply because a worker qualifies as a “minister.” Instead, courts will examine whether adjudicating the claim would require inquiry into matters of faith, doctrine, or internal church governance. The California Supreme Court has now granted review in Lorenzo, which is likely to provide further guidance on these issues.
Both Lorenzo and Ehrenkranz arose from wage‑and‑hour claims brought by former participants and staff members of the San Francisco Zen Center, a Zen Buddhist training organization that also operates income‑generating activities such as guest accommodations and event rentals. The plaintiffs performed a range of duties, including cleaning guest rooms, kitchen work, guest services, and grounds maintenance, which supported both religious practice and the organization’s commercial operations.
After the Labor Commissioner found the Zen Center and individual defendants liable for unpaid wages, overtime, and penalties, the defendants invoked the ministerial exception as a complete bar to the claims. In Lorenzo, the trial court agreed and granted summary judgment...
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