RICHMOND, VA – Liberty Counsel filed two letters of supplemental authority to the Fourth Circuit Court of Appeals in Zinski v. Liberty University regarding recent court decisions out of Washington and Minnesota that uphold the right for religious institutions to employ people aligned with their beliefs.

Two recent rulings in similar cases involving religious employment decisions favored religious institutions. On January 6, 2026, a ruling from the U.S. Ninth Circuit Court of Appeals unanimously held that the First Amendment’s Church Autonomy Doctrine entitles religious organizations to only employ people in non-ministerial roles who align with their religious beliefs. In Union Gospel Mission of Yakima Washington v. Brown, a Christian homeless shelter ministry with about 150 employees challenged a Washington state law that limits religious nonprofit ministries in decisions on who they can hire. A three-judge panel stated that the Church Autonomy Doctrine provides broad protection and prohibits intrusion by the government into the internal management decisions of religious organizations when those decisions are based on religion, including decisions involving non-ministerial level positions.

In Union Gospel, the Ninth Circuit made clear that “the First Amendment doesn’t tolerate” forcing religious institutions to employ people who “openly flout and disagree with their religious principles,” noted Liberty Counsel.

On December 1, 2025, the Minnesota Court of Appeals ruled similarly in MoChridhe v. Academy of Holy Angels. The case involved a Catholic school firing a librarian who publicly announced a gender identity change from male to female. A unanimous three-judge panel affirmed a lower court ruling dismissing the librarian’s case deciding that sex discrimination claims from non-ministerial employees “are foreclosed by the First Amendment church autonomy doctrine.”

The librarian was in a secular position and not an ordained minister, teacher or pastor at the school. Nevertheless, the court held, any discrimination claims would require the court to consider the internal church doctrine of the employment decision—something “constitutionally intolerable.”

Liberty Counsel Founder and Chairman Mat Staver said, “These recent court rulings from the Ninth Circuit and Minnesota Court of Appeals affirm that the First Amendment protects a religious institution’s right to hire only people who adhere to the same sincerely held religious beliefs. These decisions limit government interference and underscore that the Church Autonomy Doctrine protects hiring decisions beyond just ministers and extends to non-ministerial support roles. Zinski intentionally and deceptively set up Liberty University to undermine its religious beliefs and mission. However, the First Amendment allows Liberty University to determine its religious beliefs and to require employees to act consistent with those beliefs free from government interference.”

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