Revisiting Christian Legal Society v. Martinez: Reimagining the Governance of Religious Student Organizations Through the Lens of the Church Autonomy Doctrine

Authors

  • Noah Manalo

DOI:

https://doi.org/10.5195/lawreview.2026.1172

Abstract

First Amendment rights came into conflict with nondiscrimination principles in the Supreme Court’s 2010 decision in Christian Legal Society v. Martinez. This Note explains the background of the case, developments of subsequent cases, and errors in the Court’s reasoning. It then explains the proper way to resolve cases like Martinez is to apply the church autonomy doctrine to religious organizations in universities, leaving them to govern themselves. It concludes with an explanation of
the church autonomy doctrine’s application to this case, a dispelling of potential counterarguments against its application, and a call for the Court to overturn Martinez.

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Published

2026-06-30

How to Cite

Manalo, Noah. 2026. “Revisiting Christian Legal Society V. Martinez: Reimagining the Governance of Religious Student Organizations Through the Lens of the Church Autonomy Doctrine”. University of Pittsburgh Law Review 87 (3). https://doi.org/10.5195/lawreview.2026.1172.

Issue

Vol. 87 No. 3 (2026)

Section

Notes

License

Copyright (c) 2026 Noah Manalo

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