The 9th U.S. Circuit Court of Appeals found that Marc and Claire Headley, long time Scientology members, voluntarily worked at menial tasks without payment because of their commitment to the religion.
The three-judge panel, which upheld a ruling by a lower court, said the couple voluntarily abided by rules of Sea Organization, a division of Scientology with a gated campus 80 miles southeast of Los Angeles that operates as a nerve center for the church's most important business.
In a synopsis of the program, the judges acknowledged that members were forbidden to have children and Claire Headley said she had two abortions rather than risk banishment. They also had their mail censored, Internet access restricted and were required to make a symbolic one-billion-year commitment to serve the church.
The judges said members were told during training that they would be required to work long hours without compensation, to live communally and adhere to strict ethical standards.
"This demanding, ascetic life is not for everyone," said the ruling, and noted some members do decide to leave through a rigid process called "routing out" which can take weeks or months. The judges said the Headleys could have left many times.
Calls requesting comments from the couple's attorney were not immediately returned.
The judges suggested the Headleys sued under the wrong law and said other legal avenues are open to them. They sued under a statute designed to combat "transnational crime" of "trafficking in persons."
"Whatever bad acts the defendants (or others) may have committed the record does not allow the conclusion that the Church...violated the Trafficking Victims Protection act," the ruling said. The judges said the Headleys might have fared better under other legal theories such as assault, battery, false imprisonment, intentional infliction of emotional distress, or "any of a number of other theories that might have better fit the evidence."
They also said that the lower court properly rested its rulings on the ministerial exception which says courts may not scrutinize many aspects of the minister-church relationship.