Scientology did not violate a labor law by failing to pay for the work of two former members of the church's Sea Organization -- a wing that restricts participants' outside communications, marriage and children, censors mail and monitors phone calls -- a federal appeals court said Tuesday.
A three-judge panel of the U.S. 9th Circuit Court of Appeals decided that Marc and Claire Headley, who sued the church, knew that joining the group, known as Sea Org, required largely unpaid labor and failed to take many opportunities to leave.
The Headleys sued the church under the Trafficking Victims Protection Act, a federal law primarily intended to prohibit the forced labor of immigrants. A district court ruled for Scientology, and the Headleys appealed.
The former Sea Org members grew up in Scientology and joined the elite religious order while in their teens, Marc in 1989 and Claire in 1991. They married in 1992 and remained with the group until 2005. "In keeping with church disciplinary policy, the church censored the Headleys' mail, monitored their phone calls, and required them to obtain permission to access the Internet," Judge Diarmuid F. O'Scannlain, an appointee of former President Reagan, wrote for the court.
Marc and hundreds of others had to hand clean human excrement from an aeration pond in 2004, and Claire had to subsist on protein bars and water for six to eight months in 2002, O'Scannlain wrote. But the court said the evidence overwhelmingly showed that the Headleys voluntarily worked for the Sea Org "because they believed that it was the right thing to do" and "enjoyed it."
Although the couple faced the risk of being declared "suppressive persons" and possibly losing contact with family and friends if they left, that potential did not qualify as "serious harm" under the human trafficking law, the court concluded.
The panel suggested that the Headleys might have fared better had they sued on different grounds.
"They did not bring claims for assault, battery, false imprisonment, intentional infliction of emotional distress, or any of a number of other theories that might have better fit the evidence," O'Scannlain wrote.
