California Legal Brief

The Rule of Ehrenkranz v. San Francisco Zen Center is that the ministerial exception does not bar wage-and-hour claims by ministers against religious organizations absent evidence that such claims raise an ecclesiastical concern, under circumstances where the claims seek only lost or unpaid wages for work performed as part of the religious organization's commercial activities and adjudication requires no inquiry into ecclesiastical matters.

Appeal from judgment after summary judgment in Superior Court, City and County of San Francisco.

Defendant Appellant was Michael Ehrenkranz — the former Work Practice Apprentice and staff member who filed wage-and-hour claims against the Zen Center.

Plaintiff Respondents were San Francisco Zen Center, Linda Galijan, and Mike Smith — the religious organization and its former president and city center director who moved for summary judgment based on the ministerial exception.

The suit sounded in wage-and-hour violations. [No cross-claims described.]

The key substantive facts leading to the suit were Ehrenkranz participated in the Center's residential training programs from 2016-2018, first as a Work Practice Apprentice and later as staff, performing tasks including guest housekeeping, meal preparation, childcare, gardening, and cooking for paying guests at the Center's commercial operations, receiving only modest monthly stipends of $175-$245 while working 30-35 hours per week in work practice plus 20 hours of meditation and curriculum.

The procedural result leading to the Appeal: The trial court granted defendants' motion for summary judgment, ruling that Ehrenkranz's wage-and-hour claims were barred by the ministerial exception of the First Amendment because applying wage-and-hour laws to Work Practice Apprentices would create judicial entanglement in religious issues.

The key question(s) on Appeal: 1. Whether the ministerial exception bars wage-and-hour claims by ministers against religious organizations without evidence that the claims raise ecclesiastical concerns 2. Whether individual defendants found liable "as the employer" under Labor Code section 558.1 must post separate undertakings under Labor Code section 98.2(b) to appeal Labor Commissioner decisions

The Appellate Court held the ministerial exception does not categorically bar wage-and-hour claims by ministers; it only bars claims that require inquiries into matters of ecclesiastical government, and defendants presented no evidence that Ehrenkranz's claims for unpaid wages for commercial work raised any ecclesiastical concern. However, the court held only the actual employer, not individuals found liable "as the employer" under section 558.1, must post the undertaking under section 98.2(b).

The case is inapplicable when wage-and-hour claims by ministers would require judicial inquiry into ecclesiastical matters, matters of faith and doctrine, or internal church governance decisions essential to the religious institution's central mission.

The case leaves open how courts should analyze wage-and-hour claims where religious organizations present evidence that such claims do raise ecclesiastical concerns, and the broader question pending Supreme Court review of whether the ministerial exception categorically precludes all wage-and-hour claims by ministers without any inquiry into ecclesiastical concerns.