A lawsuit brought by the General Conference of Seventh-Day Adventists and Adventist Risk Management, Inc. against the State of Maryland will continue after a federal court decision on June 18, 2025, allowed several key constitutional claims to move forward. The ruling came after a hearing in which the church asked for a preliminary injunction to block Maryland’s interpretation of its Fair Employment Practices Act, while the state simultaneously moved to dismiss the case entirely.
The dispute centers on the Maryland Supreme Court’s interpretation of the law’s religious exemption, which limits the exemption to employees whose work directly furthers a religious organization’s “core mission.” Church leaders argue that this standard allows courts and government officials to intrude on internal church decisions about which roles are religiously important, potentially threatening the church’s autonomy and ability to manage its staff according to faith-based criteria.
In their lawsuit, the church and its insurer raised several constitutional objections—including alleged violations of church autonomy, free exercise of religion, and expressive association rights. The church argued that immediate court action was needed to prevent ongoing harm to their religious mission, while the state argued that the entire lawsuit should be dismissed at the outset.
Judge Theodore D. Chuang’s June 18, 2025 memorandum opinion denied the church’s request for a preliminary injunction, finding that the plaintiffs were unlikely to succeed on all their claims at this stage. However, he also declined to dismiss three central arguments, ruling that the claims regarding church autonomy, the Free Exercise Clause, and expressive association required further factual development and legal review.
This outcome leaves the case active and focused on core constitutional questions about whether Maryland’s law oversteps in defining which church employees count as religious. Both parties will now move into the next phases of litigation, with further opportunities to submit evidence and legal arguments.
General Conference of Seventh-Day Adventists v. Horton remains pending in the U.S. District Court for the District of Maryland. The timing of the next court proceedings has not yet been determined.
What this means:
This case highlights the ongoing challenge of defining the boundary between religious autonomy and state employment law. The Adventist church’s central argument is that it should have the authority to decide which positions are essential to its religious mission, relying on the First Amendment’s protection for internal church governance. The U.S. Supreme Court has affirmed this principle in decisions like Hosanna-Tabor Evangelical Lutheran Church and School v. EEOC and Our Lady of Guadalupe School v. Morrissey-Berru, both of which underscored a church’s right to make certain employment decisions free from government interference.
Maryland’s position is that anti-discrimination laws should apply to most employment relationships unless the employee’s role is directly religious. The state’s approach seeks to ensure workplace protections while still recognizing the unique status of faith-based organizations. The core of the dispute is whether the law draws this line too narrowly, potentially putting courts in the position of evaluating church doctrine or the religious significance of certain jobs.
By allowing some of the church’s claims to proceed, the federal court is signaling that the questions raised about church autonomy and the free exercise of religion are not easily resolved at the outset. The court’s approach is in line with Supreme Court guidance, which has emphasized careful factual and legal analysis in such cases.
Link to decision: https://cases.justia.com/federal/district-courts/maryland/mddce/8:2024cv02866/568430/40/0.pdf?ts=1750326929