Behrend v. San Francisco Zen Ctr., Inc., 108 F.4^th 765 (9^th Cir. 2024)

Alexander Behrend lived and worked at the San Francisco Zen Center as a work practice apprentice performing mostly menial work. In response to Behrend’s lawsuit alleging violation of the Americans with Disabilities Act, the Zen Center moved for summary judgment on the ground that the ministerial exception under the First Amendment barred Behrend’s claim. The district court granted the motion and the Ninth Circuit affirmed, holding that because Behrend lived and worked full time at the temple as a monk, he “performed vital religious duties,” and his claim therefore was barred by the First Amendment.