Claire Headley v. Church of Scientology Internat
687 F.3d 1173
| 9th Cir. | 2012Background
- Headleys joined the Sea Org, an elite religious order of the Church, with long hours, no material compensation, and a one-billion-year commitment after extensive training.
- Sea Org life imposed strict discipline, censorship of mail/communications, restricted marriage/children, and a system of routing out or leaving the ministry.
- Headleys experienced verbal and physical discipline, mandatory labor, and living constraints, including isolated or controlled access to Internet and communications.
- Claire faced pressure regarding marriage policy and left the Religious Technology Center due to restrictions; Marc remained longer but contemplated departure at times.
- Gold Base security measures, escorts, and surveillance were used to deter or monitor potential departures; many opportunities to leave existed before 2005.
- In 2009, Marc and Claire sued the Church and Center under the Trafficking Victims Protection Act (TVPA) alleging forced labor; district court granted summary judgment favoring defendants, invoking ministerial exception.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| TVPA 'by means of' coercion standard | Headleys argue psychological coercion suffices to show 'by means of' coercion. | Church/Center contend there is no such coercion evidence; acts were doctrinal and voluntary. | TVPA requires coercion via serious harm/force; record insufficient for 'by means of' coercion |
| Ministerial exception applicability | Headleys contend exception does not bar their TVPA claims. | Defendants urge exception bars claims involving ministerial labor and church practices. | Ministerial exception bars the TVPA claims here |
| Genuine issues of material fact | Headleys allege coercive conduct and retention tactics created forced labor. | Record shows voluntariness and opportunities to leave; no coercive labor under TVPA. | No genuine issues; record lacks evidence of forced-labor under TVPA |
Key Cases Cited
- Paul v. Watchtower Bible & Tract Soc’y of N.Y., Inc., 819 F.2d 875 (9th Cir. 1987) (free exercise protection for leaving or being shunned by church)
- United States v. Dann, 652 F.3d 1160 (9th Cir. 2011) (serious harm required to compel continued labor)
- Bradley, 390 F.3d 145 (1st Cir. 2004) (distinguishes improper threats from legitimate warnings of consequences)
- Hosanna-Tabor Evangelical Lutheran Church & School v. EEOC, 132 S. Ct. 694 (U.S. 2012) (ministerial exception scope in employment relationship)
- NLRB v. Catholic Bishop of Chicago, 440 U.S. 490 (1979) (constitutional avoidance in ministerial/Church governance context)