The First District Appellate Court recently reversed a trial court judgment in a wage and hour dispute. Previously, after a bench trial, the trial court had found in favor of plaintiff on her statutory claims under the Illinois Minimum Wage Law (“IMWL”) and the Illinois Wage Payment and Collection Act (“IWPCA”). The plaintiff was awarded allegedly unpaid, regular wages and overtime wages, and she was also awarded attorneys’ fees pursuant to the IWPCA’s fee-shifting provision.
In this wage and hour dispute, Johnson & Bell’s client was a religious organization which conducted sacerdotal ceremonies and meditation and lecture sessions regarding a spiritual path involving meditation and hatha yoga techniques leading toward peace or higher consciousness. In addition, the organization offered meditation teacher training and hatha yoga instructor training. It also operated a bookstore and website selling spiritual books, video lectures, and other items in an effort to fund spreading the organization’s message and mission.
Plaintiff was a member, disciple, and swami (akin to a priest) in the organization who conducted sacerdotal ceremonies. She also taught hatha yoga and meditation sessions and assisted with video presentations and website maintenance. The organization had promised to pay plaintiff for 21 hours of work per week and never promised to pay her for any work for which she had additionally volunteered to complete. After accepting payment under these terms for more than twelve years, plaintiff filed a three-count complaint, alleging that Johnson & Bell’s client had violated the IMWL and IWPCA by failing to timely pay plaintiff regular wages in excess of 21 hours per week or overtime wages, and that she was discharged in retaliation for asserting these claims. At the conclusion of the bench trial, the court ruled in favor of plaintiff on all three counts and awarded plaintiff attorneys’ fees. Johnson & Bell appealed.
The appellate court reversed the trial court’s decision on all counts in this wage and hour dispute, and reversed plaintiff’s statutory damages and attorneys’ fees awards in their entirety. First, the appellate court found the trial court erred by ignoring the evidence at trial which established that plaintiff’s employment was excepted from the IMWL because she was a member of a religious organization—referred to as the “ministerial exception” under federal law interpreting the Fair Labor Standards Act (“FLSA”) – which excepts certain employees of religious organizations from certain federal and state employment laws, including the IMWL and FLSA. Under this exception, the Illinois Minimum Wage Law is inapplicable to plaintiff’s employment because she is a member of a religious organization and is exempted from Illinois Minimum Wage Law. The appellate court found that while part of plaintiff’s work was overtly religious, as she was ordained as a swami and performed religious ceremonies, the rest of plaintiff’s work had a religious component.
Further, the appellate court also found that the trial court erred when it ruled in favor of plaintiff on her IWPCA claims because the evidence presented at trial clearly established that plaintiff had accepted the compensation she was paid without protest over a period of twelve years before filing her complaint in this matter, and that the religious organization therefore never mutually assented to pay plaintiff the wages which she alleged that she was owed (a required element of a statutory IWPCA claim).
Finally, in a concurring opinion, the concurring justice also found that the trial court erred when it found that plaintiff should have been paid for hours which she had volunteered to work as a member and constituent of the religious organization because volunteer work is excepted from the IMWL.
According to the Johnson & Bell trial team, there is a dearth of state-law precedent regarding employee wage and hour claims made under the IMWL and IWPCA. As such, the appellate court’s reversal in this case creates much needed employer-friendly precedent. In addition, this decision also created important precedent for religious organizations to continue to rely on the ministerial and volunteer work exceptions to the IMWL since many of these organizations must rely on the volunteer work of their parishioners to continue operations.