The First Amendment has limits – and a California court just drew the line
A California court ruled on March 2 that religious employers cannot use the First Amendment to automatically dodge wage claims against workers.
The decision, handed down by the California Court of Appeal, puts a meaningful limit on a legal shield that religious organizations have previously used to sidestep employment discrimination and wrongful termination lawsuits. For HR professionals at faith-based employers, the message is clear: the First Amendment is not a blanket excuse for skipping out on wage obligations.
The case centers on Michael Ehrenkranz, who joined the San Francisco Zen Center in 2016 as a residential trainee. The Zen Center, one of the largest Sōtō Zen Buddhist churches in North America, operates three temples across California. It also runs a substantial commercial operation, renting rooms to overnight guests and hosting corporate conferences for companies including Google and Facebook.
Ehrenkranz spent over two years at the Center, working in housekeeping, the kitchen, the garden, and even doing childcare for senior staff. In exchange, he received room, board, and a monthly stipend that started at $175 and peaked at $245. In November 2018, he left. In August 2020, he filed a wage claim, arguing he was owed proper minimum wages, overtime, and other compensation for the work he performed.
The Labor Commissioner agreed and awarded him $81,170.23. The Zen Center appealed, and a trial...
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