Behrend v. San Francisco Zen Ctr., Inc., 108 F.4th 765 (9th Cir. 2024)
Alexander Behrend lived and worked at the San Francisco Zen Center as a work practice apprentice performing mostly menial work. In response to Behrend’s lawsuit alleging violation of the Americans with Disabilities Act, the Zen Center moved for summary judgment on the ground that the ministerial exception under the