## Facts

- World Vision, Inc. is a Washington nonprofit, tax-exempt under 26 U.S.C. § 501(c)(3), and identifies as a Christian humanitarian organization.
- World Vision’s governing documents and policies state religious purposes and require adherence to Christian doctrines, including the Trinity and the deity of Jesus Christ.
- Sylvia Spencer, Ted Youngberg, and Vicki Hulse were employees who, at hiring, signed acknowledgments agreeing to comply with World Vision’s Statement of Faith, Core Values, and Mission Statement.
- World Vision later concluded the employees denied the deity of Jesus Christ and rejected the Trinity, which World Vision deemed incompatible with its doctrinal requirements.
- World Vision terminated the employees for failing to comply with its Statement of Faith.
- The employees alleged religious discrimination under Title VII, arguing World Vision operated primarily as a secular humanitarian organization and therefore was not a “religious corporation” exempt from Title VII’s religion-discrimination prohibition.

## Issues

1. Whether World Vision is a “religious corporation” within the meaning of Title VII’s exemption, 42 U.S.C. § 2000e-1(a), such that it may make employment decisions based on religion.
2. What criteria courts should use to decide whether an entity qualifies as “religious” for § 2000e-1(a) purposes.
3. Whether applying § 2000e-1(a) to World Vision’s employment decision raises constitutional concerns, including excessive church-state entanglement.

## Decision

- The Ninth Circuit affirmed summary judgment for World Vision.
- The court held World Vision qualified as a “religious corporation” under 42 U.S.C. § 2000e-1(a).
- The court concluded that terminating employees for rejecting World Vision’s core doctrinal beliefs constituted religion-based action permitted by the statutory exemption.
- Separate opinions agreed in the judgment while differing in how to articulate the test; a dissent would have denied exempt status.

## Legal Principles

- Title VII generally bars employment discrimination based on religion, but § 2000e-1(a) exempts a “religious corporation, association, educational institution, or society” regarding employment of persons “of a particular religion” connected to the entity’s activities.
- An entity need not be a church or house of worship to qualify as a “religious corporation”; the inquiry may include whether it is organized for religious purposes, holds itself out as religious, and conducts activities consistent with those purposes.
- Providing humanitarian services to beneficiaries without regard to their religion does not, by itself, defeat § 2000e-1(a) status; the statute does not require services to be limited to co-religionists.
- Courts should avoid tests that require evaluating the truth, centrality, or theological importance of beliefs, to reduce risks of religious entanglement.

## Conclusion

The Ninth Circuit held that World Vision’s organizational purpose, public religious identity, and faith-governed internal requirements brought it within Title VII’s “religious corporation” exemption, permitting it to require employees to comply with its Statement of Faith and to terminate employees who rejected core doctrines.


Spencer v. World Vision, Inc., 633 F.3d 723 (9th Cir. 2011)