2019 Ohio 4289
Ohio Ct. App.2019Background
- Thirty-one plaintiffs (current or former members of Mount Calvary Baptist Church, Mansfield, Ohio) sued the pastor, church officers, trustees, deacons, and the church after being notified they were no longer considered members.
- Plaintiffs alleged violations of the church constitution/bylaws and sought declaratory and injunctive relief, plus claims for breach of fiduciary duty, breach of contract, and intentional infliction of emotional distress.
- Defendants moved to dismiss for lack of subject-matter jurisdiction under Civ.R. 12(B)(1) based on the ecclesiastical abstention doctrine.
- The trial court dismissed the entire case for lack of subject-matter jurisdiction; plaintiffs appealed raising six assignments of error challenging that dismissal.
- The appellate court reviewed de novo and framed the central question as whether the disputes were ecclesiastical (barred) or secular (justiciable) given the church’s congregational governance and the bylaws’ reliance on scriptural procedures.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether civil court may adjudicate plaintiffs’ removal from church membership under congregational bylaws | Adkison: removals violated the church constitution/bylaws and are judicially reviewable as contractual/procedural violations | Williams: membership/removal is an internal, ecclesiastical matter for the congregation | Court: barred by ecclesiastical abstention; membership removals present internal governance and scriptural-interpretation issues outside civil jurisdiction |
| Whether injunctive relief can issue to prevent alleged retaliatory actions by church leaders | Adkison: injunction needed to prevent retaliation tied to membership dispute | Williams: injunction would intrude on internal church governance and is not supported by a secular interest | Court: plaintiffs’ general claim of retaliation lacked a pleaded secular basis; abstention proper and injunctive relief denied |
| Whether court can enjoin sale/encumbrance of church assets | Adkison: injunction needed to prevent disposition/encumbrance of church property | Williams: property issues are part of the internal dispute over membership and governance | Court: plaintiffs did not plead a distinct secular property/ownership interest; claim appears to be an extension of ecclesiastical dispute and is barred (neutral-principles not shown) |
| Whether breach of fiduciary duty, breach of contract, and IIED claims may proceed | Adkison: bylaws create contractual/fiduciary duties and defendants’ actions caused emotional distress | Williams: these claims are effectively challenges to internal governance and thus ecclesiastical | Court: claims are rooted in membership-removal dispute and require ecclesiastical resolution; IIED also lacks secular predicate—claims dismissed |
Key Cases Cited
- Watson v. Jones, 80 U.S. 679 (1871) (civil courts must avoid resolving ecclesiastical questions such as doctrinal interpretation or internal church governance)
- Serbian Eastern Orthodox Diocese v. Milivojevich, 426 U.S. 696 (1976) (First Amendment bars civil courts from overturning decisions of highest church judicatory on discipline, faith, or internal organization)
- Presbyterian Church in U.S. v. Mary Elizabeth Blue Hull Mem. Presbyterian Church, 393 U.S. 440 (1969) (courts may apply neutral principles of law in property disputes without resolving ecclesiastical questions)
- Minker v. Baltimore Annual Conference of United Methodist Church, 894 F.2d 1354 (D.C. Cir. 1990) (churches can be subject to contract claims in appropriate circumstances)
- Kennedy v. Gray, 248 Kan. 486 (1991) (courts have power to determine church property ownership under neutral principles)
- Heard v. Johnson, 810 A.2d 871 (D.C. 2002) (recognition that churches are not above the law, but ecclesiastical limits constrain civil adjudication)
- Tibbs v. Kendrick, 93 Ohio App.3d 35 (8th Dist. 1994) (distinguishing ecclesiastical from secular disputes in congregational churches)