The U.S. Supreme Court has held a First Amendment-based “ministerial exception” bars employees acting in a ministerial capacity from bringing certain employment claims against their religious employers. A California state court of appeal panel ruled late last month that this exception does not automatically bar a minister’s claims for failure to pay minimum wages and overtime.

Background

In Lorenzo v. San Francisco Zen Center, former San Francisco Zen Center employee Annette Lorenzo sued the center for violating California’s minimum wage and overtime laws.

The center is one of the largest Sōtō Zen Buddhist churches in North America. Its primary purpose is to encourage the practice of Zen Buddhism by operating practice facilities and educating the public about Zen Buddhism. The center ge

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