Headley v. Church of Scientology

Under the Trafficking Victims Protection Act, no genuine issue of material fact exists in a psychologically coerced labor claim where the claimant fails to show that the defendant-employer obtained the claimant’s labor “‘by means of’ serious harm, threats, or other improper methods.”

Marc and Claire Headley, ex-ministers of the Church of Scientology (“Church”), claimed that the Church forced them to “provide labor in violation of the Trafficking Victims Protection Act (“the Act”).” The Headleys argued that they were psychologically coerced by the Church to provide hard labor and stay in the ministry. In response, the Church asserted that the Headleys’ claim failed to establish a genuine issue of material fact, and was, in the alternative, precluded by the ministerial exception. The ministerial exception “provides employers with an affirmative defense to a minister’s claim when an adjudication would infringe on an employer’s religious liberty or entangle the court in a religious matter.” The district court granted summary judgment for the Church, holding that the ministerial exception barred the psychological coercion claim because it was doctrinally motivated. On appeal, the Headleys contended that an “adjudication in their favor would not infringe upon the Church’s religious liberty or entangle the court in the relationship between church and minister.” The Act bars employers from obtaining labor “by means of force, physical restraint, serious harm, threats or an improper scheme.” Little evidence suggested that the Headleys provided labor under any threat or coercion. Further, the Headleys “had multiple opportunities to leave the church” during their tenure without any serious consequences. Because the Headleys did not establish a genuine issue of material fact, the Court found it unnecessary to determine whether the ministerial exception applied. AFFIRMED.