Lorenzo v. San Francisco Zen Center

February 26, 2026

Summary of facts: A former minister of the San Francisco Zen Center sued the center for unpaid wages. A California court of appeals agreed that the plaintiff was a minister but held that the ministerial exception applies only to discrimination claims, not wage claims. The center is now asking the Supreme Court of California to hear the case.

RFI’s position: In holding that the ministerial exception applies only to discrimination claims, not wage claims, the appeals court created a clear split with the U.S. Court of Appeals for the Ninth Circuit. The court also violated the church autonomy doctrine by refusing to defer to the Zen Center’s explanation of why not paying its ministers was grounded in its faith. And the court ignored that matters of church finances, including how much and whether to pay ministers, are inherently ecclesiastical concerns. The Supreme Court of California should grant the petition for review.

Read the letter here.