Three-judge panel rules unanimously that customer service roles fall under “ministerial exception” to anti-discrimination laws
A federal appeals court on August 5 ruled that World Vision, a Christian humanitarian organization, acted within its constitutional rights when it withdrew a job offer to Aubry McMahon, a woman in a same-sex marriage, after learning of her marital status.
In a unanimous decision by a three-judge panel of the U.S. Court of Appeals for the Ninth Circuit, the court reversed a lower court ruling and held that World Vision’s customer service representative (CSR) role is covered by the “ministerial exception” to employment discrimination laws, which stems from the First Amendment’s Religion Clauses.
The panel concluded that CSRs perform “vital religious duties” central to World Vision’s mission and thus are not subject to Title VII or Washington state anti-discrimination protections.
The case began in 2021 after McMahon, who had accepted a job offer for a remote CSR position, informed World Vision via email that she and her wife were expecting a child. Days later, World Vision rescinded the offer, citing its policy requiring sexual conduct to occur only within a heterosexual marriage.
Although the district court initially sided with World Vision on religious autonomy grounds, it later reversed itself and entered summary judgment for McMahon, awarding $120,000 in stipulated damages. The court reasoned that the policy was facially discriminatory and could be evaluated under neutral legal principles.
On appeal, World Vision argued that CSRs are its public-facing representatives, who engage in prayer with donors and communicate the organization’s religious message. The Ninth Circuit agreed, emphasizing that the role involves more than administrative tasks and is integral to World Vision’s spiritual and fundraising mission.
“Without the CSRs, World Vision would be severely hindered in pursuing its central religious mission,” the panel wrote. The court declined to consider additional defenses raised by World Vision, ruling solely on the basis of the ministerial exception.
The decision was not issued en banc and represents the view of the three-judge panel only.
McMahon has not announced whether she plans to seek rehearing en banc or petition the Supreme Court for review.
Commentary:
The heart of this case is a clash between two powerful areas of law: anti-discrimination protections and religious liberty. Aubry McMahon argued that World Vision discriminated against her because of her sexual orientation and marital status when it rescinded her job offer after learning she was in a same-sex marriage. Under normal circumstances, Title VII of the Civil Rights Act and Washington’s anti-discrimination law would prohibit that.
But the “ministerial exception” changes the analysis when the job involves religious duties. This exception allows religious employers to hire and fire certain workers without court interference, even if those decisions would otherwise violate employment laws. The key question is whether the employee plays a role that furthers the religious mission of the organization.
Here, the court said that customer service representatives at World Vision do just that. Even though they answer phones and perform administrative tasks, they also pray with donors, talk about the organization’s Christian mission, and are expected to serve as the “voice” of the ministry. That, the court said, makes them “ministers” under the exception—even though they’re not clergy.
The decision was narrow in that it didn’t give all religious employers a blank check to discriminate. It focused closely on the specifics of the job and the organization’s mission. But it does signal that courts are willing to apply the ministerial exception more broadly than just to pastors and teachers, especially after recent Supreme Court cases like Our Lady of Guadalupe School.
The ruling means that in similar disputes, courts will likely look not at whether a job is overtly religious, but whether the duties help carry out the spiritual mission of the employer.
Expect this case to be cited in future litigation about the limits of anti-discrimination law when religious organizations are involved—especially in areas like health care, education, and social services.
Tags: Title VII, ministerial exception, same-sex marriage, religious liberty, World Vision
Decision link:
Aubrey McMahon v World Vision (August 5, 2025) – https://cdn.ca9.uscourts.gov/datastore/opinions/2025/08/05/24-3259.pdf
Disclaimer:
This article and accompanying illustration were produced with the assistance of artificial intelligence. All reporting is based on the official court documents. The illustration was AI-generated in the style of a linocut print to visually represent the themes of the story without depicting real individuals.