Headley v. Church of Scientology Int'l, 687 F.3d 1173 (9th Cir. 2012)

Marc and Claire Headley were ministers in the Sea Organization ("Sea Org"), which is an elite religious order of the Church of Scientology. The Sea Org demands much of its ministerial members, renders strict discipline, imposes stringent ethical and lifestyle constraints and goes to great efforts to retain clergy and to preserve the integrity of the ministry. The Headleys claimed they worked more than 100 hours per week and that each received a $50 weekly stipend as well as room and board at the Church's headquarters in Gilman Hot Springs, California. After leaving the Sea Org, the Headleys sued the Church under the federal Trafficking Victims Protection Act, which makes it a crime "knowingly" to "provide or obtain the labor or services of a person by…means of force, threats of force, physical restraint," etc. The Headleys alleged the Church "psychologically coerced" them to provide forced labor, but the Ninth Circuit affirmed summary judgment against the Headleys because "the record contains little evidence that the defendants obtained the Headleys' labor 'by means of' serious harm, threats, or other improper methods." The Court did not find it necessary to consider the applicability of the ministerial exception defense in this case.