The panel reversed the district court’s summary judgment for Aubry McMahon and remanded for entry of summary judgment in favor of World Vision, Inc., in McMahon’s lawsuit against World Vision alleging discrimination based on sex, sexual orientation, and marital status under Title VII of the Civil Rights Act of 1964 and the Washington Law Against Discrimination (WLAD).

World Vision extended a job offer to McMahon for a remote position as a customer service representative (CSR). After learning that McMahon was in a same-sex marriage, World Vision revoked its job offer.

The district court initially granted summary judgment for World Vision based on the church autonomy doctrine. Reversing itself after McMahon moved for reconsideration, the district court decided that the church autonomy doctrine did not apply because World Vision had acted under a “facially discriminatory hiring policy,” so the court could resolve the case using “neutral principles of law” without becoming entangled in religion. Rejecting World Vision’s ministerial exception defense and other defenses, the district court entered summary judgment for McMahon after concluding that World Vision rescinded her job offer
pursuant to a policy that facially discriminated based on sex, sexual orientation, and marital status in violation of Title VII and the WLAD.

Renewing on appeal the arguments it made before the district court, World Vision argued, inter alia, that CSRs fall under the ministerial exception to employment discrimination laws because CSRs serve a pivotal role in World Vision’s religious mission as its public voice.

The panel held that the district court erred by rejecting World Vision’s ministerial exception defense. The ministerial exception bars McMahon’s employment discrimination claims because the record shows that CSRs perform key religious functions central to World Vision’s mission. CSRs are responsible for effectively communicating World Vision’s worldwide ministries and projects to donors and supporters. CSRs engage with donors in prayer and give them the opportunity to join World Vision’s religious mission through financial contributions. Because each of these “vital religious duties,” Our Lady of Guadalupe Sch. v. Morrissey-Berru, 591 U.S. 732, 756 (2020), lies at the core of World Vision’s religious mission of “working with the poor and oppressed to promote human transformation, seek justice and bear witness to the good news of the Kingdom of God,” the ministerial exception applies to CSRs and bars McMahon’s claims.

The panel accordingly reversed the district court’s grant of summary judgment for McMahon and remanded for entry of summary judgment in favor of World Vision. Read more»

Judge Talman | McMahan v. World Vision | July 5, 2025

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