Drawing the Line for Religious Autonomy: Doe v. Catholic Relief Services

    Concerning religious freedom, what happens when the religious beliefs of an organization conflict with laws that protect employees from discrimination? Should religious organizations be permitted to make employment decisions according to their beliefs, even when those decisions would otherwise violate civil law? The Fourth Circuit confronted this difficult question in Doe v. Catholic Relief Services (2026), a case that illustrates the tension between religious institutional autonomy and the government's authority to enforce employment protections.

    John Doe, an openly gay man, was hired by Catholic Relief Services (CRS), a Catholic-affiliated nonprofit organization governed by the United States Conference of Catholic Bishops. During the hiring process, Doe disclosed that he was married to a man and asked whether his husband would qualify for dependent health insurance. He was told that he would. However, approximately five months after beginning employment, CRS informed Doe that providing benefits to his husband conflicted with its religious beliefs. The organization terminated the coverage and offered an alternative compensation arrangement, which Doe declined. After working for CRS for several years, Doe eventually resigned and brought claims under federal and Maryland employment-discrimination laws.

    The district court ruled in Doe's favor and CRS appealed—arguing that its religious beliefs and constitutional protections afforded it immunity from liability. On October 16, 2026, the Fourth Circuit affirmed the judgments under Title VII and Maryland's Fair Employment Practices Act, while dismissing the Equal Pay Act appeal. The majority concluded that neither the statutes nor the First Amendment provided the broad immunity CRS requested.

    The constitutional question is particularly interesting because the First Amendment protects an individual's right to believe and worship while it simultaneously protects the independence of religious institutions. In Hosanna-Tabor Evangelical Lutheran Church & School v. EEOC (2012), the Supreme Court recognized the ministerial exception, which prevents government interference with a religious institution's selection of its ministers. The Court later clarified in Our Lady of Guadalupe School v. Morrissey-Berru (2020) that an employee's actual religious responsibilities, rather than simply their job title, determine whether the exception applies. Both decisions recognize that religious organizations must retain authority over the individuals entrusted with carrying out their religious missions.

    However, the existence of institutional autonomy does not necessarily mean that religious organizations are exempt from every law governing their employment practices. The majority relied on the distinction between protected ecclesiastical matters and ordinary secular disputes. It explained that the First Amendment protects matters such as religious doctrine, ministerial employment, church membership, hierarchy, and discipline. But it does not establish a general immunity from secular laws merely because an organization invokes religious motivation. The majority also relied on the Free Exercise framework established in Employment Division v. Smith (1990). Under Smith, neutral and generally applicable laws may ordinarily be enforced even when they incidentally burden religious exercise. Church of the Lukumi Babalu Aye v. City of Hialeah (1993) and Fulton v. City of Philadelphia (2021) clarify that this protection changes when government selectively burdens religious conduct or permits comparable secular conduct. In Doe, the majority concluded that the relevant statutory exemptions did not demonstrate that religious employers were treated less favorably than comparable secular employers. For example, the small-business exemptions applied equally to religious and secular organizations.

    I find the majority's reasoning persuasive because constitutional protections should have meaningful boundaries. The First Amendment protects religious institutions' independence in matters of doctrine, religious leadership, and internal ecclesiastical governance. However, this protection does not create unrestricted immunity from neutral and generally applicable civil laws—employment decisions involving nonministerial employees do not automatically constitute matters of protected ecclesiastical governance. Since Doe's responsibilities were primarily secular rather than ministerial, CRS's sincere religious beliefs should not, by themselves, establish a constitutional exemption from generally applicable employment-discrimination laws. The conclusion does not require courts to question the sincerity or theological correctness of religious beliefs. Rather, it distinguishes between protecting religious doctrine and granting immunity to conduct regulated by civil law. If religious motivation alone were sufficient to exempt an organization from employment protections, what meaningful limits would remain? Could an organization invoke its religious identity to avoid virtually any employment obligation? The majority's approach recognizes that religious liberty cannot become a blanket exemption from the legal responsibilities shared by other participants in civil society, avoiding the slippery slope.

    Judge Quattlebaum's dissent raises an important objection; he argues that church autonomy extends beyond the ministerial exception and protects religious organizations' authority to make employment decisions reflecting their theological commitments. His concern is that requiring religious institutions to comply with laws that conflict with their beliefs can interfere with their ability to preserve their religious identity. This argument deserves consideration. Religious organizations should not be forced to surrender their convictions simply because they operate within a broader legal system. Nevertheless, institutional autonomy must be distinguished from unrestricted authority over every employment relationship. Otherwise, the scope of constitutional protection would depend almost entirely on how broadly an organization characterizes its religious mission.

    Ultimately, Doe v. Catholic Relief Services demonstrates that religious freedom and civil equality need not be mutually exclusive. The First Amendment must protect religious institutions from government interference in their distinctly religious affairs. But that protection should not automatically extend to every employment decision made in the name of religion. The challenge is not whether religious autonomy deserves protection, but is in determining where that autonomy ends and the government's legitimate authority to protect individuals under neutral civil law begins.

References

Doe v. Catholic Relief Services, No. 25-1569 (4th Cir. Oct. 16, 2026). Full opinion.

Hosanna-Tabor Evangelical Lutheran Church & School v. Equal Employment Opportunity Commission, 565 U.S. 171 (2012).

Our Lady of Guadalupe School v. Morrissey-Berru, 591 U.S. 732 (2020).

Employment Division, Department of Human Resources of Oregon v. Smith, 494 U.S. 872 (1990).

Church of the Lukumi Babalu Aye, Inc. v. City of Hialeah, 508 U.S. 520 (1993).

Fulton v. City of Philadelphia, 593 U.S. 522 (2021).

When Does Religious Freedom Become Employment Discrimination? Christian Healthcare Centers v. Nessel

 Religious freedom is a key First Amendment protection. Religious organizations can practice their beliefs, but conflicts can arise when those beliefs clash with laws that protect people from discrimination. Should these organizations be able to make hiring decisions based on their beliefs, even if it goes against state law? This is the main issue in Christian Healthcare Centers v. Nessel, a Michigan case about where to draw the line between religious freedom and employment discrimination.

Christian Healthcare Centers is a nonprofit medical group in Michigan that includes Christian beliefs in its healthcare services. Employees are expected to follow specific religious principles, such as beliefs about marriage, sexuality, and gender identity. The organization also does not provide some gender-transition treatments and does not use pronouns that differ from a patient’s biological sex at birth.

The issue centers on Michigan’s Elliott-Larsen Civil Rights Act, which bans discrimination in jobs and public services. In 2023, Michigan updated the law to clearly include protections for sexual orientation and gender identity. Christian Healthcare Centers said these changes might make them hire people who do not share their beliefs or offer services that go against their faith. The group sued Michigan Attorney General Dana Nessel and other officials, saying that enforcing these rules would violate their constitutional rights.

In August 2026, a federal district court issued a mixed ruling. It protected the organization's religious practices involving pronouns, certain medical treatments, and hiring for its Biblical Counselor and physician positions. However, the court declined to extend those protections to all other employees. Christian Healthcare Centers appealed to the Sixth Circuit Court of Appeals.

This case brings up key questions about the First Amendment’s Free Exercise Clause, which protects religious practice from unfair government limits. Christian Healthcare Centers says that being forced to hire people who do not share its beliefs would interfere with its religious mission. In their view, hiring is not simply a business matter but part of their religious practice.

On the other hand, Michigan has a duty to protect workers from discrimination. The state’s laws intend to give everyone equal job opportunities, regardless of sexual orientation or gender identity. If exemptions are too broad, these protections could be weakened, and some people might face discrimination.

A key precedent is Employment Division v. Smith (1990). In that case, the Supreme Court said that neutral laws that apply to everyone can usually be enforced, even if they affect religious practices. This means that religious beliefs do not always excuse organizations from following general laws.

However, in Hosanna-Tabor Evangelical Lutheran Church and School v. EEOC (2012), the Supreme Court recognized the ministerial exception, which protects religious organizations' authority to hire and fire employees who perform important religious functions. This matters here because Christian Healthcare Centers says its employees help carry out its religious mission. They should be allowed to practice their beliefs, but that freedom should not automatically exempt them from antidiscrimination laws. I believe courts should consider each employee's actual responsibilities and connection to the organization's religious mission rather than automatically granting exemptions for every position. 

For example, if someone teaches religious doctrine, gives spiritual counseling, or leads religious activities, it makes sense to require them to communicate the organization’s beliefs. Their job is directly tied to the religious mission. But things get more complicated for employees who mostly do administrative work or jobs not related to religious teaching.

If someone works in scheduling, billing, or another office job, should their personal beliefs about marriage or sexuality determine whether they can be hired? I think they usually should not. While the organization has religious values, these workers are not in charge of teaching or sharing those beliefs. Allowing discrimination in all jobs could make religious exemptions go further than needed to protect religious freedom.

Another consideration is that Christian Healthcare Centers offers medical care. Healthcare groups have duties to both their religious missions and their patients. I can see why some medical staff might not want to take part in treatments that go against their beliefs. Still, I think all patients deserve to be treated with respect, no matter who they are. Religious freedom should not be used as a reason to deny patients dignity or treat them unfairly. I believe the court should protect Christian Healthcare Centers’ authority to select employees for genuinely religious roles while allowing Michigan to enforce its antidiscrimination laws for other positions. Rather than automatically prioritizing religious freedom or employment equality, courts should examine the particular circumstances and responsibilities involved.

Christian Healthcare Centers v. Nessel shows how hard it is to balance two key American values: religious freedom and protection from discrimination. Both are important and should not be ignored just because they sometimes clash. I believe protecting religious freedom matters, but setting its limits is just as important for fair treatment under the law.

The Limits to Religious Freedom and Government Power: The Case of Youth 71Five Ministries

    Religious freedom is one of the Constitution's most important protections, but does the religious freedom and importance it holds in the Constitution mean a religious organization should be exempt from the rules attached to government funding? And how much excessive control should the government have over an organization’s religious practices simply because it provides financial assistance? In the case of Youth71 Five Ministries v. Williams, these questions were at the center of a 2025 Ninth Circuit Court of Appeals decision.

Youth 71 Five Ministries is a Christian nonprofit organization in Oregon that provides mentoring, youth centers, vocational training, and other programs for at-risk young people. While the organization serves youth regardless of their religious beliefs, its primary mission is to share Christianity. As a result, it requires employees and volunteers to affirm a statement of Christian faith. Since 2017, the organization has received multiple grants from Oregon’s Youth Development division. However, for the 2023-2025 grant cycle, Oregon introduced a new requirement prohibiting grant recipients from discriminating in employment based on religion and other characteristics (the state discovered this practice after receiving an anonymous complaint). Although Youth 71Five maintained its Christian hiring requirements, it certified compliance with the new policy, believing its religious practices were constitutionally protected. Oregon initially offered the organization $410,000 in grants but withdrew the money after discovering its hiring practices. Youth 71Five sued, arguing that Oregon had violated its First Amendment rights. In June 2024, the district court ruled against the ministry and dismissed its lawsuit. Later, on August 18, 2025, the Ninth Circuit partially reversed that decision: Oregon could enforce nondiscrimination requirements for state-funded grants as that is constitutionally neutral, but this non- discriminatory requirement did not extend to the ministry’s activities receiving no funding from Oregon’s Youth Development Division. The Court did not order Oregon to restore the grants.

Fundamental to this case is the Free Exercise Clause, which protects religious practice from improper government interference. One of the main constitutional debates of this case is: Is the government turning down Youth 71Five because of what they wanted to do with the grant money or because they are a religious institution? In the case of Locke v. Davey, the Supreme Court upheld Washington State’s decision to exclude students from pursuing devotional theology degrees from a publicly funded scholarship program, recognizing that the state had a legitimate interest in not funding the religious training of ministers, and this could be considered an overlap between church and state. In contrast, in the case of Trinity Lutheran Church v. Comer (2017), it was established that the government cannot deny an otherwise eligible religious organization a public benefit simply because of its religious status. This case established important protections against excluding religious organizations because of their religious status. These two cases show that the government cannot discriminate against an organization merely for being religious, but it can impose constitutional restrictions on how public funds are used; if funds are used to fund a program that has discriminatory practices, that would look as the government endorses that behaviour.

I believe that the Ninth Circuit Court applied this distinction in this case. Oregon did not deny funding simply because Youth 71Five was a Christian organization or because it promoted Christianity. This ministry intended to promote Christianity and accentuate the importance of a relationship with Jesus Christ. The Organization also required all of its employees and volunteers to affirm their Christian beliefs, which was in violation of Oregon’s nondiscrimination requirements. This is an important part of the state's argument. In my opinion, this case more closely corresponds to Locke v. Davey, while in this case it isn't a matter of the state funding a minister, a leader of a religion, this case reiterates that one can exercise their religion freely but the government can decline to subsidize certain activities. Both cases simply drew distinctions concerning funding rather than flat out excluding an applicant, because they are religious, no one told Davey that he can not pursue that theology degree, but the state can not fund it. This notion of funding a religious education also corresponds to Youth 71Five as they both consider government's discretion to fund a religious education. The state is not prohibiting Youth 71Five from practicing and spreading Christianity and even allows flexibility for Christian programs within its grant-funded initiatives. The detail of this case being that the discriminatory hiring practices would make it unconstitutional as the government would be publicly funding and there by endorsing christianity, and the turning away of people who have different beliefs. In both cases, neither government was prohibiting or regulating religious practice, but imposing limits on what they were willing to financially support. The state of Oregon continued funding faith-based organizations, but because of the ministry's failure to apply with the nondiscrimination requirements the grant was pulled.

Ultimately, I agree with the Ninth Circuit’s decision on the basis that it establishes an important balance between protecting religious freedom and allowing the government to enforce reasonable restrictions on taxpayer-funded programs. I believe and agree that religious programs, especially those looking to help troubled individuals, should have every right to practice and spread their beliefs and operate without government interference. However, religious freedom does not mean an organization receiving government funding should not adhere to non-discrimination requirements, and the government should not be funding the spreading a certain religion. The Ninth Circuit wasn’t ruling that these hiring requirements that the ministry had in place had to go away, but the government could not give them financial support while spreading a specific religion and discriminating about who is hired at the location; this is where I see contrast between this case and Trinity Lutheran Church v. Comer (2017), Youth 71Five is spreading christianity in a discriminatory manner. The First Amendment protects religious freedoms and liberties, but it doesn't guarantee access to taxpayers' money. The ministry was not denied funding because of its religious identity or its mission to spread Christianity- rather because of the requirement of employees to adhere to christian beliefs. I agree with the Ninth Circuit court because the government should be able to enforce neutral requirements when there are public funds involved without preventing religious organizations from practicing their faith. ​

Can Universities Restrict Religious Student Organizations?

        Two fundamental principles should guide public universities when creating regulations for religious student groups. First, universities have the authority to regulate student organizations. Second, universities must protect students’ right to practice their religion freely. Women of Victory at Virginia State University v. Branch (2026) raises questions about where to draw the line between these two principles. In this case, two Christian student organizations accuse Virginia State University (VSU) of religious discrimination after the university introduced a policy that removed their official recognition and required them to get permission before holding events. Based on the allegations in the complaint, I believe VSU's policy raises concerns about religious neutrality and whether its rules are generally applicable to all student organizations.

        Before this policy, Women of Victory and Bethel Campus Fellowship were registered student organizations at VSU. They could organize Bible studies, host events, and maintain relationships with their national organizations. However, when VSU introduced the new policy, both Christian groups lost their registered status and were placed under the authority of a university-appointed Campus Minister. They needed permission to hold events, invite guest speakers, and organize fundraising activities. The court stated that the Muslim Student Association and VSU Community Faith Alliance could continue operating independently. These cases show that the university did not enforce the policy uniformly. Because certain religious groups were allowed to operate independently while Christian groups were not, the university treated the groups differently.

        The Women of Victory organized an informal pajama party over Labor Day weekend. The complaint says Campus Minister Thomas Wynn criticized the group's leader for organizing the party without prior approval. The policy is alleged to have been enforced in similar cases involving Christian students. If other organizations could hold similar gatherings without permission, it would raise additional concerns about whether VSU enforced its rules neutrally. The Christian student groups sued the university in federal court on September 24, 2026. The students argued that the university violated their First Amendment rights. The two main constitutional issues are whether the policy itself is unconstitutional or whether the university is enforcing it unconstitutionally. VSU argues that the policy was developed to coordinate and manage religious activities on campus. According to Campus Minister Wynn, VSU aimed to offer guidance to students from various religious backgrounds. The right to freedom of religion prevents discrimination based on personal beliefs. I believe that the inequality shown by the university when dealing with Christian clubs is highly discriminatory and has violated the provisions of the Constitution. Even if VSU had good reasons for this policy, it needed to ensure the regulations were generally applicable.

        An important case for understanding this issue is Christian Legal Society v. Martinez (2010). In Martinez, Hastings College of the Law did not officially recognize the Christian Legal Society because its membership requirements violated the school's policy and required registered organizations to accept all students. The Christian group argued that the university discriminated based on religious belief. However, the Supreme Court disagreed, and the majority ruled that Hastings' policy was reasonable and neutral because it applied equally to every student organization. The Court explained that the Christian Legal Society was asking for an exception to a rule everyone else had to follow. The policy's equal application was important because the university did not single out Christian students for different treatment.​

        Martinez's reasoning is relevant here when considering VSU's policy. Both cases revolve around Christian groups being denied some benefit because of their officially recognized status. The only distinction here is whether the university treats all groups equally. In Women of Victory, the plaintiffs argue that the university restricts Christian groups and allows other religious groups to remain independent. While the plaintiff in Martinez sought an exemption from the rule that applied to all groups, Women of Victory and Bethel Campus Fellowship seek to be treated the same as all other groups.

        This policy raises constitutional issues. Muslim Student Association will maintain its independence, but the Christians have to be monitored by the university. The policy does not state that Christianity is being targeted, but the exemptions it provides lead to discrimination. The university's application of this policy is also an issue. It requires Christians to seek permission for any gathering, unlike others.

        I side with Women of Victory and Bethel Campus Fellowship because I do not think public universities should place greater restrictions on Christian organizations than on other religious groups. VSU has the authority to establish reasonable rules for student activities, but those rules must be neutral and applied consistently. Under Christian Legal Society v. Martinez, a university can restrict a religious organization as long as it applies equal rules to all. VSU has crossed its constitutional boundaries by treating certain religions differently.

Sources:

https://adflegal.org/article/women-of-victory-explainer/ 

https://adfmedia.org/case/women-of-victory-at-virginia-state-university-v-branch/

TST's Attempt to Celebrate the Holiday Season Becomes Extremely Controversial

In this case, The Satanic Temple Inc. and Mortimer Adramelech v. Mark Campbell, Adam Steen, and the Iowa Department of Administrative Services, we see a group of individuals seeking to freely exercise their religion within the Iowa State Capitol building. However, this practice is extremely controversial and complicated for a few reasons that we’ll dive into a little further.

The Satanic Temple sought permission to hold a one-day holiday event in the Iowa State Capitol Rotunda. This event would take place on December 12, 2026. At this event, attendees would engage in many activities such as different rituals, caroling, coloring pages for children, ornament-making for families, etc. However, the event would also include a Krampus costume contest, and this causes some concern for certain individuals.

The group had previously sought to hold events very similar to this one in 2024 and 2025 and the Iowa State Department of Administrative Services denied those applications. There was an approved event in 2023 where the group was permitted to hold a display in the Capitol alongside other groups and their displays. The Satanic Temple chose to erect a display of “Baphomet” which became controversial and was destroyed by a man who traveled all the way from Mississippi to do so. The reason for the 2024 denial was in part due to the prior vandalism, but was largely centered around the costume contest. “Krampus” is a horned figure, said to be half-goat, half-demon, and he traditionally accompanies Santa Claus during the Christmas season, most of the time carrying sticks. Legend has it that while Santa rewards well behaved children with gifts, Krampus punishes misbehaving children. Director Adam Steen, after reviewing photos of the proposed costumes, cited concerns that allowing this event to take place in the State Capitol building would be dangerous as the sticks could be used as weapons against children, and also that the event could be “harmful to minors.” After this denial The Satanic Temple offered to eliminate the costume contest and modify the event but the Department never responded to this offer. When the same application was submitted in 2025, the Department again denied it in a short email, and the event was held somewhere else.

Now in 2026, a third application was submitted back in March regarding the potential event this upcoming December. The Department initially showed some cooperation. However, Director Mark Campbell has since formally denied the application, stating that it was the very same event that had previously been rejected time and time again. Because of this, The Satanic Temple sued on claims of prohibited free speech under the First Amendment, as well as violations of the Free Exercise Clause, and concerns about equal protection. They sought a preliminary injunction requiring the State of Iowa to allow their event to proceed.

In the preliminary injunction hearing the court concluded on the following. Rather than conducting his own review, Director Campbell largely relied on Steen’s denial. In addition to that, neither one of the individuals did nearly enough research into the figure Krampus in order to make an informed decision. Less restrictive means were never considered. The denial focused more on the message or symbolism of Krampus more than any actual safety threat. And finally, the Capitol had security procedures in place to help maintain safety at the event. While no official decision has been made regarding the lawsuit, the court granted the injunction and ordered The Satanic Temple’s 2026 event application to be approved by the Department.

The constitutional question at hand in this case seems pretty straight forward at face value but answering it can become quite complex. The question I would like to address is whether or not The Satanic Temple is allowed and protected by the constitution of the United States to hold its holiday event in the Iowa State Capitol building.

From a Free Exercise perspective, The Satanic Temple as a religious group has been repeatedly burdened by the state because of its religious practices, specifically, its attempt to hold a holiday event in the State Capitol building and being denied numerous times while other religious groups had been permitted to do the exact same thing. This event was part of The Satanic Temple’s religious expression, and the denial was due to judgments about the content of the religion rather than any legitimate safety threat. The event was referred to as “evil” by Campbell and Steen, showing a great deal of hostility toward the religion because of their choice of expression, and this allows us to draw on precedents from cases like Church of Lukumi Babalu Aye v. Hialeah where government action based on hostility raises a great deal of skepticism when violations of free exercise are in question.

The question of a compelling state interest must be considered. The Department made claims of increased danger because of the event. But, the counter argument could be the fact that the Capitol had procedures in place to make sure that no dangerous objects entered the building. In my mind, this significantly weakens the argument of a compelling state interest because of “sticks” at a costume contest. If the compelling state interest is due to the potential harm done to minors because of the content, message, or symbolism being promoted at the event, that begins to blur the line between judging belief and action.

From an Establishment perspective, we must consider the issue of neutrality. The Capitol regularly permitted Christmas trees, nativity scenes, menorahs, and other holiday displays. One could say, “Well, those displays have long-standing historical significance since the religions they represent have been around for a long time.” This is unconstitutional. To say that one religion should be allowed but another should not simply based on how long each religion has been around is in violation of the First Amendment as it seeks to protect minority religions. If officials approved Christian holiday expression but excluded Satanic holiday expression because they considered it offensive, “scary,” or immoral, that suggests endorsements of some religious viewpoints over others, which is unconstitutional. The Establishment Clause prohibits the state from having the ability to decide which religions are acceptable or deserving of access to public forums.

I don’t think The Satanic Temple should have had its application denied time and time again simply because people don’t agree with their religious viewpoints. If safety were a legitimate concern, and there was enough of a compelling state interest I would have a harder time providing such an accommodation to this religious practice, however, the group agreed to modify its event, and on top of that, the state had security measures in place to ensure safety was maintained. I also don’t think the state should have the ability to restrict certain groups like The Satanic Temple from participating in this open forum while allowing groups of other religious faiths to freely practice and hold events. I would therefore deem the denials of The Satanic Temple’s holiday event in the Iowa State Capitol building unconstitutional under the First Amendment.

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Sources:

52-0-11.2.26.Order-on-PI.pdf

Can a City Restrict Religious Charity in Public Parks?

Feeding someone who is hungry seems like an ordinary act of charity. But what happens when a city requires a permit to serve food to the public in a park, while allowing private gatherings to serve food without one? That question is the focus of a lawsuit brought by St. Herman's Table, an Orthodox Christian ministry, against the City of Phoenix, Arizona.

Every Thursday, volunteers from St. Herman's Table have provided meals to people experiencing homelessness at Cave Creek Park. The ministry is associated with the Exaltation of the Holy Cross Orthodox Church, and its volunteers consider this work "almsgiving," or helping people in need as part of their religious obligations. According to the ministry's legal complaint, volunteers also distribute Bibles and offer opportunities for prayer alongside the meals.

In May 2026, Phoenix approved an ordinance requiring permits for organized food distribution and certain medical services in city parks. It allows only two service permits per eligible park each month. Organizing a covered event without a permit can result in a misdemeanor charge. Private gatherings, including family picnics and birthday parties, are exempt. St. Herman's Table sued in June, arguing that the ordinance would prevent its weekly ministry from continuing. A federal judge temporarily blocked enforcement against the ministry, finding it likely to succeed on its Free Exercise claim. On June 16, the judge extended that protection until a ruling on the next stage of the case.

The Free Exercise Clause of the First Amendment protects religious practice against unjustified government interference. Phoenix argues that its ordinance applies to religious and secular food-distribution groups alike. The city says public distributions can create crowds, trash, and competition for park space. I think those concerns deserve serious consideration. Public parks belong to everyone, and religious groups should not automatically be exempt from reasonable safety rules.

The first constitutional question, though, is whether the ordinance is neutral and generally applicable. In Employment Division v. Smith (1990), the Supreme Court held that laws meeting those requirements ordinarily can burden religious conduct without violating the Free Exercise Clause. In Tandon v. Newsom (2021), however, the Court explained that the government cannot treat comparable secular activities more favorably than religious exercise. Comparability depends on the problems the government claims to be addressing.

Phoenix does not explicitly single out religious organizations. It also regulates secular charities, which supports the city's position. But the ordinance covers organized food distribution to the general public for charitable or humanitarian purposes while exempting private gatherings. That distinction still matters if both activities create similar crowding and waste. A birthday party with thirty guests might strain park resources more than a small group handing out meals.

Phoenix has a reasonable response. Events open to the public may attract unpredictable numbers of people, last longer, or require more coordination than private celebrations. In fact, the city has cited complaints and photographs involving alleged unsanitary conditions at food-distribution events. That evidence deserves consideration, but it does not automatically establish that every distribution presents the same problems or that a two-permit limit is necessary.

This is also why Church of the Lukumi Babalu Aye v. Hialeah (1993) matters. There, the Supreme Court struck down ordinances targeting Santeria animal sacrifice while allowing comparable secular conduct. Phoenix's rule does not openly target a religion as Hialeah's did. Still, Lukumi shows why courts should look at which activities a law restricts and which it leaves alone.

If the exempt gatherings pose comparable risks, the ordinance may fail the general-applicability requirement and face strict scrutiny. That is a separate question from whether Phoenix can justify the restriction. Under strict scrutiny, the city must show a compelling government interest and that it is using the least restrictive means to achieve it. Keeping parks safe and accessible is important, and serious sanitation or safety problems could justify strong measures. But the two-permit monthly cap seems difficult to defend as the least restrictive option. Phoenix could require cleanup, regulate events according to size, or restrict activities that actually block paths and facilities. Those measures would address the city's concerns without preventing a weekly ministry from serving meals at the same park.

Phoenix's permit guidance says applications are reviewed for compliance with the city code and park rules. But that does not solve the problem of a ministry that wants to serve the same community every Thursday. Two permits per month cannot accommodate that schedule.

I would rule in favor of St. Herman's Table if Phoenix cannot show why the exempt gatherings are less likely to create the problems it identifies. If the activities are comparable, I do not think the city has shown why a fixed permit cap is necessary when less restrictive options exist. Religious charity should not be above ordinary park rules, but neither should it face stricter rules without a convincing reason.

Does Religious Freedom Apply to Everyone?

        Religious freedom is one of the most important rights protected by the First amendment, but sometimes it becomes controversial when the religion involved is unfamiliar or unpopular. This issue came up recently in Iowa after the state repeatedly denied the Satanic Temple permission to hold a holiday event inside the State Capitol. While other religious groups were allowed to use the space, the Satanic temple got turned away over concerns about their activities. The case raises a question about whether the government can treat religious groups differently even if their beliefs make some people uncomfortable.

The Satanic Temple has been trying to organize a winter holiday event inside the Iowa State Capitol rotunda for years now. The organization describes itself as a non-theistic religious group, which means its members don’t believe in a literal Satan. Instead, the group promotes ideas like individual freedom and separation of church and state. In 2023, the group was allowed to place a holiday display in the Capitol alongside other religious displays. However, the display was vandalized, and the group faced increased hostility afterward.

In 2024, the Iowa Department of Administrative Services denied the group’s application to hold another holiday event. The proposed event had activities such as singing carols, making ornaments, coloring pages for children, and a Krampus costume contest. Krampus is a character from European folklore who is often portrayed as a frighting figure carrying sticks. State officials argued that the costumes could scare children and that the sticks could create safety concerns. The Satanic temple argued these reasons were just being used to prevent them from using the space to express their beliefs.

In August 2026, the Satanic Temple filed a federal lawsuit against the state. The group argued that Iowa had violated their constitutional rights to religious freedom, free speech, and equal protection. On November 2nd, federal Judge Stephanie Rose ordered Iowa to allow the Satanic Temple’s event. The judge found the Satanic Temple was likely to succeed on its free speech claim and questioned whether the state’s safety concerns actually justified banning the entire event. However, the state appealed the decision, and the lawsuit is still ongoing. This ruling was an important victory for the group though.

The main constitutional issue in this case involves the Free Exercise Clause and the Free Speech Clause of the First Amendment. The Free Exercise Clause protects people’s ability to practice their religion without unfair government interference. The Free Speech Clause also prevents the government from discriminating against certain beliefs simply because officials disagree with them. Since Iowa allows religious organizations to use the Capitol, the question is if they can exclude the Satanic temple while continuing to allow other groups.

One Supreme Court case this connects to is Advisory Board v Pinette. In this case the Supreme Court ruled that a privately sponsored religious display could be placed in a public area that was open to different forms of expression. The circumstances were different, but the decision established that religious expression does not lose constitutional protection just because it takes place on government property. I think it’s especially important because allowing the Satanic Temple to hold an event doesn’t mean the government supports their beliefs.

Personally, I agree with the judges decision to allow this event. I understand why people feel uncomfortable with the Satanic temple’s imagery, especially considering the religious beliefs many Americans associate with Satan. However, I don’t think personal disagreement with a religion should determine whether it receives constitutional protection. If Christians organizations are allowed to hold events in the Capitol, the Satanic temple should have the same opportunity.

At the same time, I do believe that the state has a responsibility to protect visitors and make sure events are appropriate. If they had legitimate safety concerns about certain planned activities, they should be allowed to address them. However, outright banning the entire event does seem a little excessive when smaller restrictions could solve the problem. For example, the state could enforce the same rules about potentially dangerous objects and props that would apply to every organization.

Ultimately, I believe the courts should rule in favor of the Satanic Temple if the evidence continues to show that Iowa treated the group differently just based on their beliefs. Religious freedom should apply to everyone equally, regardless if their religion is widely accepted. Allowing the event wouldn't mean Iowa supports the Satanic temple, but rather that the state is respecting the constitutional rights of all religious groups.

Fight the Fire or the Contagious Disease

During the Covid-19 Pandemic, the development of the Covid-19 vaccine was an important development to help prevent the spread of this infectious and contagious disease. Many businesses, like Snohomish Regional Fire and Rescue, made policies mandating the vaccine with religious exemptions. However, many individuals did not want to receive the vaccine, with religious beliefs being a very common reason for not wanting to receive the vaccine. In Snohomish Regional Fire and Rescue, twenty-five percent of their staff filed for a religious accommodation to not have to receive the Covid-19 vaccination. The response from Snohomish Fire and Rescue was for these firefighters to have an unpaid suspension. From this, eight firefighters filed a lawsuit against Snohomish Regional Fire and Rescue for wrongful discrimination under Title VII of the Civil Rights Act, which prohibits employment discriminating by race, color, religion, sex, and national origin. 

Thus the question is if the unpaid suspension of the firefighters of the Snohomish Regional Fire and Rescue is an unconstitutional infringement of their free exercise rights as guaranteed by the First Amendment? This issue has been brought to the attention of the Washington District Court and the Court of Appeals for the Ninth Circuit. 

A relevant Supreme Court that relates to this case is Groff v. Dejoy (2023), which discussed postal worker Groff seeking a religious accommodation to not work on Sundays. Groff was a devout Christian, which the postal services knew when hiring him, and accepted that he would not take Sunday shifts. Their solution to when Groff was out on a schedule for a Sunday, that he could swap shifts with another coworker. In spite of this seemingly easy solution, many times Groff was left without coverage, and would not go to work in compliance with his religious beliefs. Yet it is this exact action that got him fired. When this court eventually reached the supreme court it was unanimously ruled in favor of Groff. In addition, the decision also set a precedent that for an employer to deny a religious accommodation they must prove an undue burden onto the business.

In the case of the Snohomish Regional Fire and Rescue, the eighth firefighters suing believe that their wrongful lack of accommodation to their religious practice is analogous to the postal worker Groff. These firefighters have a deep religious convocation preventing them from receiving the vaccine, and thus believe their religious accommodation should be granted. They also argue that these firefighters did follow all other covid procedures, such as wearing a mask and social distancing. However the fire department argues that it's simply not enough. In addition, neighboring fire departments did not have the same restrictions for those who filled out religious exemptions. In fact, some of the plaintiffs were able to work at one of these firehouses, and even worked alongside Snohomish Regional Fire and Rescue on many calls.  

On the other hand, Chief of Snohomish Regional Fire and Rescue believes that by accommodating these religious beliefs that there is an undue burden on the department. In their case, they state that there is a health and safety cost, a financial cost and  an operational burden associated with allowing these firefighters to continue to work while not vaccinating for Covid-19. In terms of health and safety, the fire department argues that by not getting vaccinated these individuals imposed a risk on the public and their coworkers. Since these firefighters were also EMT/parameter certified, they can easily get the public sick with their job. Thus the department wanted to prevent any potential harm to the general public. 

Beyond the outreach of their jobs, the fire department also states that there is potential harm in getting other firefighters sick since Covid-19 is contagious. This not only imposes a health risk to themselves, but also creates a financial burden. When coworkers contract an infectious and contiguous disease, then there are more people taking sick days, and if enough people must take off then it could require hiring more people. In addition to this financial cost, there is also a case specific cost for Snohomish Regional Fire and Rescue. This specific fire and rescue worked with a local Department of Corrections as their primary point of contact for emergency services. To work with this DOC, Covid-19 vaccinations were required for the organizations that worked with them. Thus by having members of the fire and rescue team who were not required, they would no longer be able to respond to these calls. 

Lastly Snohomish Regional Fire and Rescue displays that by accommodating the religious exemptions imposes an operational burden. Since twenty-five percent of the department's fire fighters filled out this religious accommodation form, they argued that it was proportionally too many people to properly accommodate for one of their policies. These financial, operational, and health and safety burdens were enough for the ninth-circuit court to say there was an undue burden to accommodate the religious exemptions. Petersen and the other plaintiffs petitioned their case to the supreme court, but were denied. 

In my opinion, I agree with the decision of the Ninth Circuit Court that the burden on Snohomish Regional Fire and Rescue do constitute the burden on the firefighters. For protecting the health of the public and their coworkers, I believe they have shown the compelling state interest of preventing the spread of a contagious illness. Since preventing the spread of Covid-19 is of an important interest, it justifies the lack of religious accommodation. This also supports the precedent of Groff, as all the burdens associated with granting the religious exemptions are an undue burden that justify the denial of the religious exemption. In addition, I believe by not allowing them to work at Snohomish Regional Fire and Rescue they are only placing an indirect burden, as they can still continue to believe their religious convictions, they just simply can not be a fire fighter at this specific station. Thus I believe the Ninth Circuit Court has made the right decision in supporting Snohomish Regional Fire and Rescue. 

Resources: 

https://www.oyez.org/cases/2022/22-174

https://firstliberty.org/snohomish/

https://www.heraldnet.com/2026/10/05/scotus-wont-hear-snohomish-co-firefighters-vaccine-lawsuit/

https://law.justia.com/cases/federal/appellate-courts/ca9/24-1044/24-1044-2025-09-02.html

Should Faith Healing practices be protected or prosecuted?

 

Is refusing medical care for one’s children based on religious beliefs child endangerment or protected religious practice? Pennsylvania courts are in the midst of deciding this in the case of Connie and Martin Deimler, who are charged with child endangerment. The couple allegedly failed to provide medical care to their children, leading to the death of an infant and severe illness of a toddler. The couple held sincere religious beliefs in the efficacy of faith to heal the sick, and against the use of medical treatment. I think that in this case, the government has a compelling interest to protect the welfare of children even if it restricts free exercise of religion. 

On December 12, 2025, EMS and State police were called to the Deimler home in Lebanon County, PA in response to the death of their 6-day-old son. The infant died from complications from neonatal hyperbilirubinemia and multiorgan dysfunction. The couple had not received prenatal care or medical care after birth. State troopers also discovered that the couple had another young child with significant medical issues. That child was taken in for surgery immediately, and Connie and Martin were instructed on how to care for that child’s medical and nutritional needs. After the couple allegedly failed to follow those instructions, the child was placed in the custody of Lebanon County Child services on December 29, 2025. On April 23, 2026, both parents were charged with two cases of felony child endangerment. Under the statute they are charged with violating, child endangerment is defined as a parent knowingly endangering the welfare of a child by violating their duty of care, protection, or support. The statute is neutrally written and includes no text allowing for religious exemptions.

The Lebanon Branch of Faith Tabernacle Congregation

Connie and Martin Deimler are members of Faith Tabernacle Congregation. Faith Tabernacle Congregation is a small non-denominational fundamentalist Christian church. Key to the religious practice of Faith Tabernacle is a belief in faith to heal the sick. As an extension of this belief, members of the church completely eschew any medical treatment, including vaccines and lifesaving treatment. Started in Philadelphia in 1897, Faith Tabernacle Congregation has a long history of legal issues due to their trust in faith healing, from a 1906 case of a child dying from untreated typhoid fever to members being forcibly vaccinated in a 1991 measles outbreak. The church has historically been insular and follows a variety of other fundamentalist practices in addition to faith healing.

At the heart of the case is a question over the limits of the state in protecting children from harmful effects of religious belief. How far does the free exercise clause go in permitting parents to subject their children to their religious beliefs? While no Supreme Court cases have directly dealt with similar faith healing situations, a few dealing with the broader issue of parental authority are helpful in understanding the constitutional context of Commonwealth of Pennsylvania v. Martin Deimler and Commonwealth of Pennsylvania v. Connie Deimler.

Prince v. Massachusetts concerns the ability of members of the Jehovah’s Witnesses to enlist children to distribute religious literature in violation of child labor laws. Ruling in favor of Massachusetts, the Court decided that the government has broad authority to regulate the treatment of children, beyond what would be considered unconstitutional restriction of free exercise of religion for adults. The majority opinion notably asserts that “Parents may be free to become martyrs themselves. But it does not follow they are free, in identical circumstances, to make martyrs of their children…” This statement has proven to be grimly prescient in the Deimler case. The state has a compelling interest to protect the welfare of the child under the legal principle of parens patriae, and this interest can override the free practice of religion.

In Wisconsin v. Yoder, the Court ruled in favor of the old Amish Community allowing them a religious exemption to mandatory schooling laws. The majority opinion appeals to the long history of the Amish in living separately from the world, and to the fact that the contested practice is “intimately related to daily living.” This decision protects the ability to gain exemptions from laws that overly burden foundational religious practices, even if those laws are neutrally written and applied.

While Faith Tabernacle Congregation is not quite as insular as the Amish, I think that it is comparable to the Amish in many ways. Like the Amish, the church has a long history of religious practice that runs counter to the mainstream. If the specific practice were less harmful, perhaps the child endangerment statute could have a religious exemption such as Wisconsin v. Yoder helps establish. It's clear that the statute heavily burdens a practice that is foundational to members of Faith Tabernacle Church: the ability of parents to trust in God to heal their children. However, this situation is a literal case of life and death, which easily meets the standard of a state’s compelling interest to protect a child’s wellbeing. For this reason, I agree with Lebanon County prosecutors that neglecting medical care for children is felony child endangerment. 

Currently, the two cases are being processed by the Lebanon County Court of Common Pleas. If the two are found guilty, I think it is unlikely that religious exemptions to the child endangerment statute will be considered, based on both Pennsylvania and Federal precedent. Moreover, under the principle of parens patriae, I feel that the state is fully valid in prosecuting this case.