On October 2, 2024, the General Conference of Seventh-day Adventists (GC), together with Adventist Risk Management (ARM), filed a verified complaint in the United States District Court for the District of Maryland. This legal action raises important questions about the intersection of religious freedom and employment law, particularly concerning the ability of religious organizations to make hiring decisions in alignment with their religious beliefs. The case, General Conference of Seventh-day Adventists v. Cleveland L. Horton, II, challenges a reinterpretation of the Maryland Fair Employment Practices Act (MFEPA) that threatens the religious autonomy of organizations like the Seventh-day Adventist Church.
Nature of the Case
At the heart of the lawsuit is the plaintiffs’ assertion that Maryland’s current interpretation of employment law infringes on their First Amendment rights. Specifically, the plaintiffs argue that the state’s application of MFEPA, following a 2023 ruling by the Maryland Supreme Court in Doe v. Catholic Relief Services, improperly restricts their ability to hire only Seventh-day Adventists for positions within their organizations. The GC and ARM claim that this restriction violates their religious liberty by interfering with their constitutionally protected autonomy to make employment decisions based on faith.
According to the complaint, the plaintiffs contend that the First Amendment’s Religion Clauses should protect their right to ensure that all employees adhere to and uphold the Seventh-day Adventist faith, regardless of their specific job duties. They also argue that Maryland’s legal framework, as currently applied, would require secular courts to assess religious doctrine to determine which positions further the religious mission of an organization, a practice that would lead to excessive entanglement of church and state.
Background on the Seventh-day Adventist Church
The Seventh-day Adventist Church, one of the most racially and ethnically diverse Christian denominations worldwide, traces its origins to a religious revival movement in the 1840s. Officially established in 1863, the church has grown to over 22 million members globally, with ministries spanning education, healthcare, and humanitarian aid. Central to the church’s mission is a commitment to sharing the teachings of the Bible and preparing believers for eternal life with Christ.
The General Conference, the church’s highest governing body, plays a vital role in overseeing the administration of the church’s global operations, including the management of personnel who carry out the church’s work. ARM, on the other hand, provides insurance and risk management services to Adventist ministries worldwide. Both organizations maintain that hiring individuals who share their faith is crucial to advancing the church’s mission.
The Legal Conflict: MFEPA and the Doe v. Catholic Relief Services Decision
For many years, MFEPA, Maryland’s anti-discrimination law, included a broad religious exemption, allowing religious organizations to hire based on faith without fear of violating state law. However, in 2023, the Maryland Supreme Court reinterpreted this exemption in Doe v. Catholic Relief Services, significantly narrowing its scope. The court held that the exemption applies only to employees whose jobs directly further the “core” religious mission of the organization. This decision means that roles deemed by a court to be non-religious, such as janitorial or administrative positions, would not qualify for the exemption, even if the organization requires those employees to adhere to religious beliefs.
This reinterpretation, according to the plaintiffs, leaves them vulnerable to legal action if they continue to require all employees to be members of the Seventh-day Adventist Church, regardless of job function. Under this new standard, even positions like a building services technician would no longer be protected under the religious exemption, exposing the GC and ARM to liability if they refuse to hire individuals who do not share their faith.
Claims for Relief: First Amendment Violations
The plaintiffs’ complaint alleges that the application of MFEPA, as reinterpreted by the Maryland Supreme Court, violates multiple constitutional protections. These include:
Church Autonomy (First Amendment Religion Clauses): The plaintiffs argue that MFEPA unlawfully interferes with their ability to make internal religious decisions, such as determining which employees are qualified to work within their organization based on faith. They claim that the law intrudes on the church’s governance by forcing secular courts to decide what constitutes the church’s “core mission” and which roles further that mission (Complaint, pp. 20-21).
Excessive Entanglement (First Amendment Establishment Clause): The plaintiffs assert that MFEPA results in excessive entanglement between church and state by requiring secular courts to interpret religious doctrine and assess which job functions are essential to the church’s mission. This entanglement, they argue, violates the Establishment Clause, which mandates the separation of church and state (Complaint, pp. 21-22).
Denominational Discrimination (First Amendment Establishment Clause): The plaintiffs also claim that the reinterpreted MFEPA discriminates against religious organizations with broader understandings of their mission. Religious groups that see all employees as integral to their faith mission, regardless of job title, are disadvantaged compared to those that limit faith-based hiring to religious or pastoral roles (Complaint, pp. 26-27).
Free Exercise of Religion (First Amendment): The plaintiffs contend that MFEPA’s current application burdens their religious exercise by restricting their ability to hire employees who share their faith. They argue that this burden is not justified by a compelling government interest and, therefore, fails to meet the strict scrutiny standard required when laws restrict religious freedom (Complaint, pp. 23-25).
Expressive Association and Right of Assembly (First Amendment): The complaint further claims that MFEPA infringes on the plaintiffs’ right to expressive association by compelling them to employ individuals who do not share their religious beliefs. They argue that this forced association dilutes their religious message and undermines their ability to create a community of believers dedicated to carrying out the church’s mission (Complaint, pp. 28-30).
The Broader Implications
This case could set a significant precedent for religious organizations across the United States. If the plaintiffs succeed, the decision could reaffirm the broad protections religious groups have historically enjoyed in making faith-based employment decisions. A ruling in favor of the General Conference and ARM would likely strengthen the autonomy of religious institutions to define their own missions and determine which employees are necessary to fulfill them without interference from the state.
However, if the court upholds Maryland’s current interpretation of MFEPA, it could signal a shift toward more restrictive interpretations of religious exemptions in employment law. Such a ruling could open the door for increased government oversight of religious organizations’ hiring practices, potentially forcing them to justify their employment decisions based on secular standards of job function rather than their religious beliefs.
