A legal dispute involving San Francisco Zen Center has taken a new turn following a ruling by a California appellate court, reopening wage-and-hour claims brought by a former monk-in-training, and raising broader questions about how state labor law applies to religious training programs.
The case centers on Annette Lorenzo, who lived and trained at San Francisco Zen Center between 2015 and 2019. Lorenzo participated in the organization’s residential work practice program, first as a Work Practice Apprentice and later as staff. In July 2020, she filed a claim with California’s Labor Commissioner, alleging that she was owed unpaid minimum wages, overtime pay, and related penalties for work performed during her time at the center.
Following an administrative hearing, the Labor Commissioner ruled in Lorenzo’s favor, awarding her US$149,177.15 in unpaid wages, liquidated damages, interest, and waiting-time penalties. The award also held two Zen center leaders individually liable under California Labor Code section 558.1 as persons “liable as the employer.”
The Zen center appealed the decision to the San Francisco Superior Court, arguing that the First Amendment’s “ministerial exception” barred Lorenzo’s claims. The ministerial exception is a legal doctrine recognized by US federal courts that protects the autonomy of religious organizations in matters concerning the selection, supervision, and compensation of ministers.
The trial court agreed with the Zen center and dismissed Lorenzo’s claims. However, on 21 November 2025, the California Court of Appeal reversed that ruling. The appellate court held that the ministerial exception does not automatically exempt religious organizations from complying with state wage-and-hour laws, particularly where adjudicating such claims does not require courts to resolve questions of religious doctrine or internal governance.
In its decision, the court stated that “religious employers are not categorically exempt from wage and hour obligations under state law,” and emphasized that the ministerial exception “is not an umbrella immunity.” Rather, the court said, it was limited to situations involving “strictly ecclesiastical matters, such as the selection or removal of ministers.” (Deseret News)
The appellate ruling allows Lorenzo’s claims to proceed unless the case is taken up by the California Supreme Court.
San Francisco Zen Center operates as a nonprofit religious corporation and runs three training temples: City Center in San Francisco, Tassajara Zen Mountain Center, and Green Gulch Farm in Marin County. In addition to residential Buddhist training programs, the organization generates revenue by renting rooms to non-practicing guests and hosting retreats and events. At Tassajara, members of the public may use the hot springs and baths without being required to practice Buddhism.
According to court records, work practice is described by the Zen center as an integral part of Zen training, with tasks such as gardening, cooking, cleaning, and administrative work undertaken as forms of mindful practice. During her time at San Francisco Zen Center, Lorenzo cleaned guest rooms, washed laundry, gave tours, worked in kitchens and bathhouses, assisted the executive chef, and later served as a librarian. Her final monthly stipend was US$198.33.
Supporters of San Francisco Zen Center argue that applying wage laws to such arrangements threatens long-standing religious traditions. On 29 January, John Garvey, former president of The Catholic University of America, filed a friend-of-the-court brief supporting the Zen center. Garvey argued that requiring religious institutions to comply with California wage laws in such contexts would undermine practices that have “been respected and practiced for centuries,” citing Catholic vows of poverty and similar monastic commitments. (Deseret News)
Eric Rassbach, vice president and senior counsel at Becket, a Washington, DC-based law firm focused on religious freedom, also criticized the appellate ruling. “A Buddhist monk in training and a Catholic seminarian aren’t your average 9-to-5 gigs, and courts shouldn’t treat them as such,” Rassbach said (Becket). He added: “Disputes over ministerial compensation invariably drag judges into matters of religious doctrine and practice,” and warned that the ruling “pull[s] courts into religious questions the Constitution says they must leave alone.” (Deseret News)
The appellate court’s decision does not preclude San Francisco Zen Center from later presenting evidence that applying labor laws in Lorenzo’s case would create unconstitutional entanglement with religious practice. For now, however, the ruling signals that religious and mission-driven nonprofits operating revenue-generating programs may face closer scrutiny when spiritual training overlaps with operational labor.
A decision on whether the California Supreme Court will hear the case is expected later tbis year.
See more
This Buddhist Zen Center is at the heart of a battle for religious freedom (Deseret News)
California court reinstates Zen Center wage claims, tosses leaders’ appeals (HRD Magazine)
California high court urged to protect Zen Buddhist monastery (Becket)
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