Claire Headley v. Church of Scientology Internat

We consider two former ministers’ claims that the Church of Scientology forced them to provide labor in violation of the Trafficking Victims Protection Act.

I

This case centers around the Church of Scientology International (the Church) and its component Sea Organization (or Sea Org). The Church exercises overall ecclesiastical management of the Scientology religion. The Sea Org is an elite religious order of the Church and acts as Scientology’s evangelical wing. The Sea Org demands much of its members, renders strict discipline, imposes stringent ethical and lifestyle constraints, and goes to great efforts to retain clergy and to preserve the integrity of the ministry. These features of the Sea Org flow from the teachings and goals of the Scientology religion.

Scientology teaches that man is an immortal spiritual being that, over time, becomes distressed as his mind experiences moments of pain or lowered consciousness. Scientology maintains, however, that man can overcome that distress — he can become “clear” — by using methods developed by Scientology founder L. Ron Hubbard. Scientology aims to disseminate Hubbard’s teachings to “clear the planet” — that is, to help…