The panel affirmed the district court’s preliminary injunction prohibiting the enforcement of the Washington Law Against Discrimination (“WLAD”) against the Union Gospel Mission of Yakima, Washington—a Christian ministry—for preferring and hiring co-religionists for non-ministerial roles. WLAD prohibits employment discrimination based on several protected grounds, including sexual orientation. Because of its religious purpose, Union Gospel requires its employees to agree with and live out its Christian beliefs and practices, including “abstaining from any sexual conduct outside of biblical marriage between one man and one woman.” Union Gospel brought this pre-enforcement action against the Washington State Attorney General and the Washington State Human Rights Commission, alleging violations of the First Amendment and requesting an injunction prohibiting defendants from enforcing WLAD against it.

The panel held that Union Gospel is likely to succeed on the merits of its claim that enforcing WLAD against it for hiring only co-religionists violates the church autonomy doctrine, as established by the First Amendment’s Religion Clauses. The church autonomy doctrine encompasses more than just the ministerial exception. It forbids interference with “an internal church decision that affects the faith and mission of the church itself.” In this case, Union Gospel’s co-religionist hiring policy constitutes an internal management decision that is essential to the institution’s central mission. It is uncontested that (1) Union Gospel is a religious institution, (2) Union Gospel has a sincerely held religious belief that only co-religionists may advance its religious mission, and (3) Union Gospel’s co-religionist hiring policy is based on that religious belief.

Under the church autonomy doctrine, Union Gospel may decline to hire as non-ministerial employees those who do not share its religious beliefs about marriage and sexuality. But unlike the ministerial exception, the church autonomy doctrine protects only Union Gospel’s non-ministerial hiring decisions based on religious beliefs. Union Gospel cannot discriminate on any other ground. The panel emphasized that its decision was limited to religious organizations like Union Gospel and that it did not consider the scope of the doctrine on other types of entities run by religious institutions, such as businesses or hospitals.

The panel held that the remaining preliminary injunction factors—irreparable harm, the public interest and balance of the equities—favored Union Gospel.

United States Court of Appeal for the Ninth Circuit, Union Gospel Mission of Yakima, WA v. Nick Brown et al. | January 6, 2026.

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