[24-154] Catholic Charities Bureau, Inc. v. Wisconsin Labor & Industry Review Commission

Catholic Charities Bureau, Inc. v. Wisconsin Labor & Industry Review Commission

Justia · Docket · oyez.org

Argued on Mar 31, 2025.

Petitioner: Catholic Charities Bureau, Inc.
Respondent: Wisconsin Labor & Industry Review Commission.

Advocates:

• Eric C. Rassbach (for the Petitioners)
• Curtis E. Gannon (for the United States, as amicus curiae, supporting the Petitioners)
• Colin T. Roth (for the Respondents)

Facts of the case (from oyez.org)

Catholic Charities Bureau (CCB) is the social ministry arm of the Diocese of Superior in Wisconsin, operating since 1917 to provide services to the poor and disadvantaged as an expression of the Catholic Church's social ministry. The organization is controlled by the bishop of the Diocese, who serves as CCB’s president and appoints its membership. CCB’s mission is to provide service to people in need and advocate for justice, with a philosophy rooted in being “an effective sign of the charity of Christ.” The organization makes no distinctions based on race, sex, or religion in its services, employment, or board appointments.

Under CCB’s umbrella are four sub-entities involved in this case: Barron County Developmental Services, Black River Industries, Diversified Services, and Headwaters. These entities provide various social services, including job placement and coaching for people with disabilities, community-based training, daily living services, and support programs. While CCB oversees these sub-entities and provides management services, the sub-entities themselves are primarily funded through government contracts and do not receive direct funding from the Diocese. Neither employees nor service recipients are required to be of any particular religious faith, and the programs do not provide religious training or attempt to promote the Catholic faith.

CCB and its sub-entities sought an exemption from state unemployment insurance contributions in 2016, but the Department of Workforce Development denied the exemption. An administrative law judge reversed that decision, but then the Labor and Industry Review Commission (LIRC) reversed again, finding the organizations were not operated primarily for religious purposes. Then, the circuit court sided with CCB, and then the Wisconsin Court of Appeals reversed and reinstated LIRC’s decision. Ultimately, the Wisconsin Supreme Court affirmed, holding that the organizations did not qualify for the religious purposes exemption under state law.

Question

Does a state violate the First Amendment’s religion clauses by denying a religious organization an otherwise-available tax exemption because the organization does not meet the state’s criteria for religious behavior?