SEATTLE – A federal appeals court has invoked the church autonomy doctrine in an employment dispute with potential implications for Pagan and other minority religious organizations. The ruling, issued January 6, 2026, centers on the First Amendment’s Religion Clauses and clarifies the scope of that church autonomy doctrine. While the case arises from a Christian organization, the court’s reasoning extends beyond Christian religious organizations and their approach to hiring decisions.
The lawsuit involves the hiring practices of the Yakima Union Gospel Mission and has become a case to watch in the ongoing national debate over the boundaries between religious freedom and workplace anti-discrimination laws. The unanimous decision by the Ninth Circuit U.S. Court of Appeals affirmed a preliminary injunction allowing the Christian nonprofit to continue its faith-based hiring practices, even (and importantly) for non-ministerial positions, despite Washington State’s anti-discrimination law.
Image credit: Blogtrepreneur – CC BY 2.0, https://commons.wikimedia.org/w/index.php?curid=50979400
The Basics of the Case
The Yakima Union Gospel Mission is a private, nonprofit Christian ministry that operates a homeless shelter, addiction-recovery programs, meal services, outreach efforts, and health clinics in Yakima, Washington. According to the organization, it serves anyone in need regardless of background or belief. However, it maintains that its religious mission requires employing only those who share and live out its Christian beliefs, including its understanding of marriage and sexuality.
Washington’s Law Against Discrimination (WLAD) prohibits employment discrimination based on sexual orientation, gender expression, or identity, among other protected categories. While WLAD contains an exemption for religious organizations, that exemption was narrowed in recent years by Washington courts. In 2021, the Washington Supreme Court construed WLAD’s religious-employer exemption narrowly, limiting it to ‘ministers’ as defined in federal First Amendment cases. That earlier case, unrelated to the Yakima litigation, involved a denial of employment to an applicant in a same-sex relationship.
In early March 2023, Yakima Union Gospel Mission filed a pre-enforcement lawsuit against Washington’s attorney general and the Washington State Human Rights Commission. The Mission argued that the Washington Supreme Court’s 2021 decision narrowing WLAD’s religious-organization exemption stripped religious organizations of long-standing protections and exposed the ministry to enforcement for its non-ministerial hiring practices.
Although the state was not actively investigating the mission, the organization argued that the credible threat of enforcement was already interfering with its ability to hire employees in roles like IT technician and operations assistant.
Initially, U.S. District Court Judge Mary K. Dimke dismissed the case, agreeing with state officials that the lawsuit was an improper attempt to relitigate the 2021 state Supreme Court ruling. However, in August 2024, a three-judge panel of the Ninth Circuit reversed that dismissal, holding that the mission had standing to sue and sending the case back to the district court.
On remand, Judge Dimke granted a preliminary injunction barring the state from enforcing WLAD against the mission’s co-religionist hiring practices. The state appealed, leading to oral arguments in June 2025 and, then, last week’s appellate decision affirming the injunction.
Seal of the U.S. Ninth Circuit Court of Appeals [public domain]
What the Ninth Circuit Actually Held
The Ninth Circuit’s ruling does not resolve the case on its merits. Rather, it holds that Yakima Union Gospel Mission is likely to succeed, and therefore should not face enforcement while litigation continues.
Crucially, the court did not rely primarily on the ministerial exception, the doctrine that allows religious organizations to hire and fire clergy without government interference. Rather, it grounded its decision in the broader church autonomy doctrine, which protects a religious organization’s internal decisions about faith, doctrine, and mission from state intrusion.
Writing for the panel, Judge Patrick J. Bumatay stated, “If a religious organization’s hiring of co-religionists for non-ministerial positions rests on its sincerely held religious beliefs, then the church autonomy doctrine forbids government interference with that hiring decision.”
The court emphasized that the mission’s beliefs were sincere, that its hiring policy was rooted in those beliefs, and that staffing decisions were integral to how it understood and carried out its religious mission. Because enforcing WLAD would require the state to second-guess those religious judgments, the First Amendment barred such enforcement.
The decision aligns the Ninth Circuit with recent Supreme Court trends emphasizing institutional religious autonomy. But the panel repeatedly stressed that its ruling is narrow.
What the Decision Does (and Does Not) Do
The court was explicit about the limits of its ruling. It does not allow discrimination on non-religious grounds, such as race or national origin, nor protect religious organizations acting for purely secular reasons. Also, it does not automatically apply to other entities run by religious organizations, such as businesses or hospitals.
Instead, constitutional protection applies only when the hiring decision is rooted in a sincerely held religious belief, the decision affects the organization’s internal faith and mission, and the organization is clearly religious in nature.
Courts, the decision noted, may still scrutinize sincerity, reject pretextual claims, and enforce neutral laws where religion is not genuinely implicated. This is not a “religion wins everything” ruling, but a reaffirmation that religious institutions retain the right to define themselves.
What This May Mean for Pagan and Other Minority Religious Organizations
Although the plaintiff is a Christian mission, the Ninth Circuit’s reasoning is religion-neutral. In principle, it applies to any religious organization, including Pagan, Indigenous, and other minority traditions.
Because this ruling comes at the preliminary-injunction stage and is framed narrowly, any application to other faith communities will depend on the organization’s structure, documentation, and the religious nature of the role. Still, for Pagan organizations, the decision supports an important constitutional principle: when a religious organization sincerely believes that hiring only co-religionists is essential to carrying out its religious mission, the First Amendment can prevent the state from interfering, even for non-ministerial roles.
In practical terms, this means that Pagan organizations may limit certain positions to Pagans when the restriction is rooted in sincerely held religious belief and tied to the organization’s religious mission. For example, roles involving ritual leadership, stewardship of sacred space, instruction in religious practice, or participation in oath-bound or initiatory traditions. The protection does not depend on formal clergy titles, but on whether the role is understood by the organization to be religious in function related to its mission.
The earlier limits also apply. Pagan organizations cannot rely on this decision to justify discrimination based on non-religious categories, nor can they invoke religion as a post-hoc justification for decisions that are actually secular or personal in nature. Vague preferences, cultural comfort, or political alignment will not suffice. Claims must be sincere, consistent, and grounded in lived religious practice.
The ruling underscores the importance of clarity. Organizations that articulate their religious nature, document their beliefs and practices, and clearly explain how particular roles support their religious mission are far better positioned to claim constitutional protection than those that might identify themselves as a cultural identity rather than a religious discipline.
Future legal battles are likely to focus on how far non-ministerial protections extend, how courts assess sincerity without entanglement, and whether states rewrite statutory exemptions to avoid constitutional conflict. If other circuits diverge, Supreme Court review is possible.
For now, the Ninth Circuit’s decision marks a significant decision: it affirms that religious autonomy is not limited to clergy alone, and that all religious organizations appear to have constitutional protections when their practices are genuinely religious and mission-driven.
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