Seattle's Union Gospel Mission v. Woods, 21-144

Seattle’s Union Gospel Mission is a tax‑exempt religious nonprofit that requires staff to affirm a statement of faith and comply with a biblical lifestyle policy proscribing homosexual behavior; the staff‑attorney role included spiritual duties.
Matthew Woods, a bisexual former volunteer, disclosed his sexual orientation when inquiring about a staff‑attorney opening; he was told he could not apply and later was not hired; a co‑religionist was hired.
Woods sued under Washington’s Law Against Discrimination (WLAD), alleging sexual‑orientation discrimination; the Mission invoked WLAD’s statutory exemption for religious organizations and the First Amendment.
The trial court dismissed under the WLAD exemption, finding the position involved ministerial/spiritual functions; the Washington Supreme Court reversed, holding the exemption could not be applied broadly and should be confined to ministerial claims under state constitutional principles, and remanded to determine whether the staff attorney qualifies as a minister.
The U.S. Supreme Court denied certiorari; Justice Alito (joined by Justice Thomas) filed a statement respecting the denial, warning that the question whether First Amendment church‑autonomy protections extend beyond formal ministers may require future review and noting jurisdictional/finality issues in the case’s posture.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Applicability of WLAD's religious‑employer exemption to the Mission's hiring decision	WLAD bars sexual‑orientation discrimination; exemption shouldn't shield this hire	WLAD exempts religious orgs; hiring decision relied on religious requirements	WA Supreme Court: exemption narrowed to ministerial claims; remanded to decide minister status; SCOTUS denied cert.
Scope of First Amendment church‑autonomy (ministers‑only vs. broader)	First Amendment doesn't protect secular hiring decisions; protection limited	Religious autonomy protects hiring of co‑religionists for roles integral to mission, not just formal ministers	State court assumed protection only for ministers; Alito's statement argues autonomy likely broader; cert denied.
Conflict with Washington Constitution (privileges/immunities)	Broad religious exemption would infringe state constitutional protections for sexual orientation	Legislature intended the exemption to protect religious missions from compulsion	WA Supreme Court confined exemption to avoid state constitutional conflict.
Justiciability / final‑judgment jurisdiction for SCOTUS review	State decision is interlocutory; SCOTUS lacks jurisdiction now	Petitioner asserts Cox Broadcasting jurisdiction; urges review	Alito: interlocutory posture and lack of First Amendment ruling by state court counsel denial; certiorari denied without prejudice.

Hosanna‑Tabor Evangelical Lutheran Church and School v. EEOC, 565 U.S. 171 (recognizing ministerial exception and special solicitude for religious autonomy)
Our Lady of Guadalupe School v. Morrissey‑Berru, 591 U.S. (applying ministerial‑exception principles)
Corporation of Presiding Bishop of Church of Jesus Christ of Latter‑day Saints v. Amos, 483 U.S. 327 (upholding statutory exemptions for religious employers)
Watson v. Jones, 13 Wall. 679 (1872) (early, broad principles excluding civil adjudication of internal church matters)
Kedroff v. Saint Nicholas Cathedral of Russian Orthodox Church in N. Am., 344 U.S. 94 (protecting religious organizations from secular control)
Cox Broadcasting Corp. v. Cohn, 420 U.S. 469 (jurisdictional principles regarding final state judgments)
Little v. Wuerl, 929 F.2d 944 (3d Cir. 1991) (circuit precedent protecting religious‑organization autonomy)
Kennedy v. St. Joseph’s Ministries, Inc., 657 F.3d 189 (4th Cir. 2011) (circuit treatment of religious employer hiring autonomy)