Aubrey McMahon v. World Vision Inc.
In 2020, Aubrey McMahon applied for an administrative position with World Vision Inc., a Christian-based nonprofit organization that provides humanitarian services to fight hunger and poverty. After further interviews for the Customer Service Representative position at World Vision Inc., McMahon was denied employment due to a conflict with World Vision's Standard of Conduct policy. McMahon, a female, is married to another woman. After finding this information out, World Vision let McMahon know that they could not go further with the employment because she had violated the SOC policy stating that World Vision does not tolerate “sexual conduct outside the Biblical covenant of marriage between a man and a woman.” McMahon then sued World Vision Inc. under unlawful discrimination due to the basis of sex, sexual orientation, and marital status in violation of Title VII and the Washington Law Against Discrimination. In 2023, the District Court of Washington ruled in favor of McMahon on the ground that World Vision's policy was facially discriminatory, denying World Vision's claim of a ministerial exemption. Ministerial exception applies to individuals who perform “vital religious duties” that are “essential to the institution’s central religious mission.” Following the district court's ruling, World Vision Inc. appealed to the Ninth Circuit under the question of whether their biblical marriage standard of conduct policy facially discriminates against sex, sexual orientation, marital status under Title VII, and the WLAD, or can World Vision establish an exemption by concluding that the CSR (customer service representative) position qualifies for the ministerial exemption.
Determining ministerial exemption in this case required the Ninth Circuit Court of Appeals to refer to prior cases such as Hosanna-Tabor Evangelical Church and School v. EEOC, Our Lady of Guadalupe School v. Morrissey-Berru, and Behrend v. S.F. Zen Center. In 2011, the Supreme Court set a precedent for ministerial exemptions in the case of a school teacher who also served as a minister at the School and Church, and was fired. The Supreme Court decieed these 4 components need to be considered, “(1) the employee’s formal title; (2) the “substance reflected in that title,” such as “a significant degree of religious training followed by a formal process of commissioning”; (3) the employee’s use of that title; and (4) whether the employee performed important religious functions.” However, they also argued that these components should not be used as a checklist to be weighed together, but instead to guide the court in its consideration of such cases. These guiding principles were also used in determining a ministerial exemption in Our Lady of Guadalupe, where the Supreme Court decided that what matters most in terms of granting ministerial exemption is what matters at the very bottom, and what an employee does, and whether they perform “vital religious duties.” After this notion was created in the Supreme Court, in the case of Behrend, the Ninth Circuit Court of Appeals claimed that “the ministerial exception applied to Behrend because, although he performed mostly menial work, that work was itself 'an essential component of Zen training.” In all three cases, the main exception concerned the notion of vitality in the positions and religious duties. Each institution was granted an exemption because the position in question had vital religious responsibilities and therefore the religious entity was able to be selective even if it was presumed to be discriminatory.
Based on these precedent cases. The Ninth Circuit of Appeals in the case World Vision Inc. v. McMahon granted a ministerial exemption to World Vision, in disagreement with the district court's opinion. World Vision’s mission statement describes the non-profit's purpose as to “follow the lord and Savior Jesus Christ in working with the poor… and bear witness to the good news of the Kingdom of God.” Not only does their mission statement show how deeply religious and devoted this organization is, but it also describes the CSR employment position as a vital role in its mission. The CSR position reaches out to donors and solicits donations, viewing World Vision as a ministry. As employees in CSR, not only do they collect donations but also participate and even are expected to lead worship and teach potential donors about World Vision's mission, as well as the witness of Jesus Christ. For these reasons, the Ninth Circuit Court of Appeals viewed the employment responsibilities of a Customer Service representative as requiring the performance of vital religious duties at the heart of World Vision's religiously rooted mission.
I agree with the Ninth Circuit's ruling. In my opinion, World Vision Inc. should be granted ministerial exemption because of its deeply rooted Christian belief system, which not only informs its mission statement but also permeates its employees. In the eyes of Biblical standards, any sexual conduct should only be between a man and a woman. Therefore, to accommodate an employee such as Aubrey McMahon would be asking World Vision to completely disregard their devout religious beliefs about marriage that are reiterated in every connection with donors for their nonprofit when reciting their mission and their savior, Jesus Christ. In understanding precedents such as Hosanna, Our Lady of Guadalupe, and Behrend, I resonate with the idea of vitality in performing religious duties. The employees of World Vision are not only employees but also ministers of the foundation, and they perform employee-wide prayer and worship. Forcing World Vision to hire employees who go against all foundational beliefs about marital status and sexual orientation according to the Bible would be unconstitutional and go against their First Amendment Rights according to the Free Exercise Clause, and is therefore why they were and should be granted a ministerial exemption.
References:
https://www.oyez.org/cases/2019/19-267
https://www.oyez.org/cases/2011/10-553
https://www.aclu.org/cases/aubry-mcmahon-v-world-vision-inc
https://cdn.ca9.uscourts.gov/datastore/opinions/2025/08/05/24-3259.pdf
https://firstliberty.org/news/federal-appeals-court-protects-freedom-of-religious-groups-in-hiring/
https://cdn.ca9.uscourts.gov/datastore/opinions/2024/07/17/23-15399.pdf?lctg=123645130
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