"[3] The Church acknowledged that the rules under which the Headleys lived included a ban on having children, censored mail, monitored phone calls, needing permission to have Internet access and being disciplined through manual labor.

[4] The court found that the church enjoyed the protection of the free exercise of religion clause in the First Amendment, and that the "ministerial exemptions" in employment law prevented the government from interfering in the treatment of its ministers.

The court also found that it did not need to reach whether the ministerial exception would bar a claim under the TVPA [Trafficking Victims Protection Act of 2000], since the Headleys did not establish a genuine issue of fact as to whether the church obtained their labor 'by means of' improper conduct.

The Court suggested that other claims might have withstood appellate review, had the Headleys brought them, such as assault, battery or "any of a number of other theories that might have better fit the evidence.

As author of the Court's opinion, Judge Diarmuid F. O’Scannlain wrote: The act bars an employer from obtaining another's labor 'by means of' force, physical restraint, serious harm, threats or an improper scheme ... That text is a problem for the Headleys because the record contains little evidence that the defendants obtained the Headleys' labor 'by means of' serious harm, threats or other improper methods.

[8] Tampa lawyer Greg W. Kehoe, a 25-year Justice Department veteran, stated, "Here is a court saying, albeit in a civil situation ... that there is nothing improper with this type of conduct and no ill motive can be imbued to the church.