The DOL’s allegations are pretty offensive. Not only did it claim that all of the restaurant’s employees worked for free, it also claimed that the ministry coerced church members into volunteering, telling them they “had an obligation to provide their labor to the Buffet, in service to God, and that a failure to offer their labor to the Buffet … would be the same as failing God;” that Angley “was God’s prophet, and saying ‘no’ to Angley would be tantamount to saying ‘no’ directly to God,” and “‘blaspheming against the Holy Ghost.’”
Last year, in a scathing opinion, U.S. District Court Judge Benita Pearson ordered Angley and his church to pay employees more than $388,000 in unpaid wages and liquidated damages.
Yesterday, however, the 6th Circuit reversed [pdf].
The 6th Circuit opinion rests on two key points.
- If individuals providing services to a religious organization “did not work in expectation of compensation,” they are volunteers, not employees. Therefore, their free work does not violate the FLSA.
- The FLSA does not prohibit the type of “spiritual coercion” alleged in this case. It “does not go so far as to regulate when, where, and how a person may volunteer her time to her church. After all, the giving of one’s time and money through religious obligation is a common tenet of many faiths.”