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9th Circuit Backs Religious Mission Against Washington Bias Laws

The Ninth Circuit Court of Appeals affirmed a preliminary injunction protecting Union Gospel Mission of Yakima Washington from enforcement of state anti-discrimination laws. The court held that the faith-based organization can require employees to adhere to Christian beliefs in non-ministerial positions.

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4 min readcourtlistener
Seal of the Ninth Circuit Court of Appeals

Case Information

Case No.:
24-7246

Key Takeaways

  • Ninth Circuit affirmed preliminary injunction protecting Union Gospel Mission from Washington state anti-discrimination law enforcement
  • Court held that Christian ministry can require employees in non-ministerial roles to adhere to religious beliefs
  • Decision based on First Amendment protections and church autonomy doctrine against state civil rights enforcement

The Ninth Circuit Court of Appeals affirmed a district court ruling that protects Union Gospel Mission of Yakima Washington from enforcement of the Washington Law Against Discrimination in a decision filed Jan. 6, 2026. The three-judge panel upheld a preliminary injunction that allows the Christian ministry to prefer and hire co-religionists for non-ministerial roles without violating state employment laws.

The case, *Union Gospel Mission of Yakima Washington v. Brown* (9th Cir. 2026), pitted the faith-based organization against Washington Attorney General Nick Brown and officials from the Washington State Human Rights Commission. The dispute centered on the mission's employment practices and whether state anti-discrimination laws could be enforced against religious organizations for their hiring decisions.

Union Gospel Mission requires all employees to agree with and live out Christian beliefs and practices, including "abstaining from any sexual conduct outside of biblical marriage between one man and one woman." The organization argued that these requirements are protected under First Amendment religious freedom guarantees and the church autonomy doctrine.

The Washington Law Against Discrimination prohibits employment discrimination based on several protected grounds, including sexual orientation. State officials sought to enforce these provisions against the mission, leading to the constitutional challenge in federal court.

The U.S. District Court for the Eastern District of Washington, presided over by Judge Mary K. Dimke, initially granted Union Gospel Mission's request for a preliminary injunction. The state officials appealed that decision to the Ninth Circuit.

Circuit Judges Johnnie B. Rawlinson, Daniel A. Bress, and Patrick J. Bumatay heard oral arguments on June 3, 2025, in Seattle. Judge Bumatay authored the panel's opinion affirming the lower court's ruling.

The decision relied heavily on First Amendment protections and the church autonomy doctrine, which generally shields religious organizations from government interference in matters of faith and internal governance. Courts have consistently recognized that religious institutions have broad discretion in selecting employees who will carry out their spiritual mission.

The panel's ruling allows Union Gospel Mission to continue requiring employees in non-ministerial positions to adhere to the organization's religious beliefs and moral standards. This extends beyond traditional ministerial roles to include other positions within the faith-based organization.

The case reflects ongoing tensions between religious freedom protections and state civil rights laws. Religious organizations have increasingly sought exemptions from anti-discrimination statutes, arguing that compliance would violate their constitutional rights to free exercise of religion.

For Washington State, the decision limits the scope of WLAD enforcement against religious employers. The state had argued that its compelling interest in eliminating discrimination justified applying the law to religious organizations' employment practices.

The Ninth Circuit's opinion joins a growing body of federal appellate decisions that have strengthened religious employer exemptions. The Supreme Court has signaled support for broad religious liberty protections in recent years, particularly in employment contexts.

Union Gospel Mission operates as a Christian ministry providing social services and religious programming in Yakima. The organization's mission includes serving homeless individuals and families while maintaining its religious character through employee conduct standards.

The preliminary injunction remains in effect while the underlying case proceeds in district court. State officials have not announced whether they will seek further appellate review of the decision.

The ruling affects how Washington enforces its anti-discrimination laws against religious employers throughout the state. Other faith-based organizations may cite the decision when defending their employment practices against state civil rights enforcement actions.

Legal observers note that the decision aligns with broader trends in religious liberty jurisprudence that favor institutional autonomy over government regulation. The church autonomy doctrine has emerged as a powerful defense for religious organizations facing civil rights challenges.

The case number is 24-7246, and the district court case was designated 1:23-cv-03027-MKD. The panel's published opinion will serve as binding precedent within the Ninth Circuit's jurisdiction, which includes Washington State.

As the case returns to district court for further proceedings, both sides will likely prepare for continued litigation over the scope of religious exemptions under federal constitutional law. The preliminary injunction provides temporary relief for Union Gospel Mission while broader questions about the intersection of religious freedom and civil rights law remain unresolved.

Topics

First AmendmentChurch Autonomy DoctrineEmployment DiscriminationReligious FreedomLGBTQ RightsCivil Rights

Original Source: courtlistener

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