## Facts

- A church-affiliated nonprofit gymnasium open to the public employed Arthur Frank Mayson for about 16 years.
- The gym was operated by corporate entities associated with the Church of Jesus Christ of Latter-day Saints.
- Mayson and four other employees were terminated because each could not or would not satisfy the Church’s “temple recommend” (worthiness) requirements.
- The discharged employees held positions characterized as nonreligious and alleged unlawful religious discrimination under Title VII.
- The employer relied on Title VII § 702, which exempts religious organizations from Title VII’s prohibition on religious discrimination in employment.

## Issues

1. Whether Title VII § 702’s exemption for religious organizations violates the Establishment Clause when applied to employment decisions involving secular, nonministerial jobs within a religious organization.
2. Whether the exemption lacks a sufficient secular purpose or has the primary effect of advancing religion under the Establishment Clause analysis.

## Decision

- The Supreme Court reversed the judgment that had found § 702 unconstitutional as applied.
- The Court held that applying § 702’s exemption to a religious organization’s secular activities does not violate the Establishment Clause.
- The Court concluded the exemption permissibly relieves governmental interference with religious organizations’ ability to define and carry out their missions.
- The Court reasoned that the exemption does not constitute governmental advancement of religion because the government is not itself sponsoring or endorsing religious activity.
- The Court emphasized that an across-the-board exemption reduces, rather than increases, government entanglement by avoiding official line-drawing between “religious” and “secular” functions.

## Legal Principles

- Government may accommodate religion by lifting regulatory burdens on religious exercise without violating the Establishment Clause, so long as the government does not sponsor or endorse religion.
- Under Establishment Clause analysis, a law is not unconstitutional merely because it allows religious organizations to advance religion; the constitutional focus is on whether the government itself advances religion.
- A legislative purpose to alleviate significant governmental interference with religious organizations’ missions is a permissible secular purpose.
- Avoiding governmental inquiries into the religious character of an organization’s functions and employment practices can mitigate excessive entanglement concerns.

## Conclusion

The Court upheld Title VII § 702 as a permissible accommodation, allowing religious organizations to apply religious criteria to employment decisions even for secular jobs, because the exemption reflects neutrality toward religion and reduces governmental entanglement rather than establishing religion.


Corp. of the Presiding Bishop of the Church of Jesus Christ of Latter-Day Saints v. Amos, 483 U.S. 327 (1987)