(CN) - Two former Scientologists who worked 100-hour weeks for a pittance, foregoing family life and following behavioral codes, cannot advance forced-labor claims, the 9th Circuit ruled Tuesday.
Marc and Claire Headley met and married in the 1990s within Sea Org, an elite and evangelical Scientology religious order. Both had grown up in Scientology and opted to make the "symbolic one-billion-year commitment" required of Sea Org ministers. For nearly two decades, the couple lived the "demanding ascetic life" typical of Sea Org.
Their behavior was constantly monitored and subject to correction, usually through manual labor. Members are prohibited from having children, required to adhere to a strict moral and ethical code, and discouraged from ever leaving Sea Org and its mission to "clear the planet," the court found.
The Headleys served their time in Sea Org primarily at the church's international headquarters in Gilman Hot Springs, Calif., called Gold Base. They say that they were required to work more than 100 hours per week in exchange for room, board and a $50 weekly stipend. Marc produced training films, and Claire "advanced to a senior ecclesiastical position," according to the court. They both left Sea Org and Scientology in 2005.
The couple sued the Church of Scientology in 2009, alleging violations of the Trafficking Victims Protection Act. They claimed that the church had coerced them into believing that they could not leave Sea Org without suffering serious harm, and thus their labor all those years had been forced. Claire claimed that she had undergone two abortions in the mid-1990s, fearing the hard labor and other consequences that she would face otherwise.
The allegations failed to convince U.S. District Judge Dale Fischer in Los Angeles. He found that the Headleys' claims were barred by the First Amendment's ministerial exception, which discourages courts from getting involved in disputes over church activities that are "doctrinally motivated."
Affirming unanimously, a three-judge panel of the 9th Circuit found that the ministerial exception does not even apply here because the Headleys failed to show that they were forced into anything.
"The record overwhelmingly shows that the Headleys joined and voluntarily worked for the Sea Org because they believed that it was the right thing to do, because they enjoyed it, and because they thought that by working they were honoring the commitment that they each made and to which they adhered," Judge Diarmuid O'Scannlain wrote for the federal appeals court in Pasadena. "We think it telling that the Headleys protest very little about their actual day-to-day jobs with the Sea Org - for Marc, film creation and production; for Claire, management and supervision. Instead, they focus their attack on the discipline, lifestyle, and familial constraints imposed as part of Sea Org life. But the record does not suggest that the defendants obtained the Headleys' labor 'by means of' those features of Sea Org life. To the contrary, the record supports the conclusion that such features caused Marc and Claire to leave the Sea Org and thus to stop providing labor. Marc left the Sea Org after he was told that he could be subjected to manual labor and could otherwise face discipline. Claire left after she was unable (in light of a restrictive marriage policy) to keep her position in the Religious Technology Center-the very position in which, she now contends, she was long forced to labor." (Emphasis and parentheses in original.)
There is nothing to support the Headleys' alleged fears about the trouble in store for those who left Sea Org, the panel found.
"The security that they decry afforded them a multitude of opportunities to leave, as hundreds of other Sea Org members had done - whatever their commitments and whatever they may have been told regarding the permissibility of leaving," the ruling states. "For example, although Marc had an escort on a trip to New York, his testimony makes clear that he could have just left despite his escort; and Claire left the Sea Org during a trip to an optometrist - despite the escort that was accompanying her. They did not take any of their many opportunities to leave until 2005 and chose instead to stay with the defendants and to continue providing their ministerial services. They have not established a genuine issue of fact regarding whether they were victims of forced-labor violations."
Church of Scientology attorney Eric Lieberman, with Rabinowitz, Boudin, Standard, Krinsky & Lieberman in Manhattan, said Tuesday's ruling "resoundingly rejects the claims and puts the entire thing in the proper context."
"This was a religious order in which they were involved," he told Courthouse News.
"They didn't live on the base, so in effect they chose every day whether or not to go to work," he said.
The Headleys' attorney, Kathryn Saldana, with Metzger Law Group in Long Beach, Calif., could not be reached for comment.