McMahon v. World Vision Inc, 2:21-cv-00920

Background:

Plaintiff Aubry McMahon, an openly gay woman in a same-sex marriage who became pregnant, received a written offer (DSR Trainee) from World Vision in January 2021.
World Vision is a Christian ministry whose Articles of Incorporation, Statement of Faith, and internal policies (CCW, BECC, SOC) require staff to uphold religious teachings, including a standard that sexual expression is confined to marriage between a man and a woman.
After McMahon emailed the recruiter to ask about leave for her upcoming childbirth and thus disclosed she was married to a woman, World Vision rescinded the job offer, citing her inability to affirm and comply with its Standards of Conduct.
McMahon sued under Title VII and the Washington Law Against Discrimination (WLAD) for sex, sexual-orientation, and marital-status discrimination; both parties moved for summary judgment.
The court held it had subject matter jurisdiction over the federal claims but concluded the Church Autonomy Doctrine foreclosed adjudication of McMahon’s employment-discrimination claims because resolving pretext would require questioning World Vision’s religious doctrine and the sincerity/weight of that doctrine.
The court denied McMahon’s partial summary judgment, granted World Vision’s summary judgment, and dismissed McMahon’s claims on Church Autonomy grounds without reaching whether the ministerial exception applied.

Issues:

Issue	Plaintiff's Argument	Defendant's Argument	Held
Subject-matter jurisdiction — whether federal courts may hear this dispute	Title VII creates federal question jurisdiction; related state claims are supplemental	First Amendment religio‑theological dispute bars federal jurisdiction	Court: federal jurisdiction exists; First Amendment defenses are affirmative, not jurisdictional
Whether Church Autonomy Doctrine bars McMahon’s claims	Claims are ordinary discrimination (sex, sexual orientation, marital status) and thus adjudicable	Doctrine bars inquiry because rescission was religiously motivated and adjudication would require resolving religious doctrine	Court: Doctrine bars claims — neutral-principles resolution not possible without questioning religious doctrine
Whether World Vision’s religious justification is pretext	McMahon contends the stated reason is pretext for unlawful discrimination	World Vision says rescission rested on sincere, doctrinal requirement; plaintiff offered no secular proof of pretext	Court: Plaintiff failed to show pretext via secular evidence; proving pretext would impermissibly require probing religious beliefs
Applicability of ministerial exception and religious exemptions	McMahon: exceptions do not automatically preclude her claims	World Vision: First Amendment doctrines (ministerial exception, church autonomy, religious-organization exemptions) bar claims	Court: Did not decide ministerial exception; resolved case on Church Autonomy Doctrine and granted summary judgment for World Vision

Key Cases Cited

Our Lady of Guadalupe Sch. v. Morrissey-Berru, 140 S. Ct. 2049 (2020) (ministerial-exception principle protecting religious employers’ autonomy in employment decisions)
Hosanna-Tabor Evangelical Lutheran Church & Sch. v. E.E.O.C., 565 U.S. 171 (2012) (ministerial exception bars certain employment discrimination suits by ministers)
Kedroff v. Saint Nicholas Cathedral of Russian Orthodox Church in N. Am., 344 U.S. 94 (1952) (First Amendment protects religious institutions’ control over internal governance and doctrine)
Serbian E. Orthodox Diocese for U. S. of Am. v. Milivojevich, 426 U.S. 696 (1976) (civil courts must refrain from resolving church doctrinal disputes)
Jones v. Wolf, 443 U.S. 595 (1979) (neutral-principles exception permitting adjudication without resolving doctrinal issues when possible)
Bollard v. Cal. Province of the Soc’y of Jesus, 196 F.3d 940 (9th Cir. 1999) (employment-related harassment claims may proceed if resolvable on secular grounds)
Elvig v. Calvin Presbyterian Church, 375 F.3d 951 (9th Cir. 2004) (ministerial-exception and church-autonomy defenses are not jurisdictional bars to suit)
DeMarco v. Holy Cross High Sch., 4 F.3d 166 (2d Cir. 1993) (pretext inquiry must focus on secular facts, not the truth of religious doctrine)
Butler v. St. Stanislaus Kostka Cath. Acad., 609 F. Supp. 3d 184 (E.D.N.Y. 2022) (refusing to permit pretext inquiry that would require questioning religious doctrine in same-sex‑related termination)
Bostock v. Clayton Cnty., Ga., 140 S. Ct. 1731 (2020) (Title VII prohibits discrimination based on sexual orientation)
Reeves v. Sanderson Plumbing Prods., Inc., 530 U.S. 133 (2000) (plaintiff retains ultimate burden to prove intentional discrimination and pretext)