Ambush v. Mount Zion Baptist Church, Inc. ex rel. Board of Trustees
88 So. 3d 1077
La. Ct. App.2012Background
- Mount Zion Missionary Baptist Church, Inc. in Alexandria, Louisiana, is embroiled in a church governance dispute among its members and leadership.
- Over 130 church members filed suit seeking relief and challenged the church’s leadership and election processes.
- The trial court appointed a special master to oversee an annual meeting and election of a new Board of Trustees, and granted injunctive relief to ensure access to the church.
- The May 1, 2011 election occurred before this appeal was heard, and the plaintiffs later contested the validity of that election.
- Ambush v. Mount Zion Baptist Church, Inc. (La.App. 3 Cir. 2011) held that the May 1 election was null and void due to the suspension of injunctive relief; this appeal challenges the trial court’s actions and seeks to affirm or remand for further proceedings.
- This appeal is part of a broader litigation related to Mt. Zion’s internal governance following a related pastor/board dispute (Mt. Zion v. Ameal Jones, Sr., 11-961).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the court properly appointed a special master | Plaintiffs contend the appointment is justified by exceptional circumstances. | Church argues consent of all parties is required under La.R.S. 13:4165(A). | Special master appointment affirmed due to exceptional circumstances. |
| Whether the injunction improperly limited the trustees’ duties | Plaintiffs argue the injunction improperly restricted the Board's authority. | Church argues the injunction was overbroad and encroaches on governance. | Trial court’s injunction upheld; not an abuse of discretion. |
| Whether the May 1, 2011 election was void | Plaintiffs maintain the election should be deemed valid notwithstanding prior rulings. | Church asserts continued validity despite suspension issues. | Election void; precedential status affirmed under Ambush ruling. |
Key Cases Cited
- White v. Bd. of Dirs. of St. Elizabeth Baptist Church, 974 So.2d 164 (La.App. 2 Cir. 2008) (appointment of a special master may be warranted in church governance disputes when formalities are at issue)
- Ambush v. Mount Zion Baptist Church, Inc., 84 So.3d 674 (La.App. 3 Cir. 2012) (May 1, 2011 election null and void after injunctive relief suspension)
- LeBlanc v. Davis, 432 So.2d 239 (La.1983) (courts generally refuse to interfere in ecclesiastical matters, but may adjudicate procedure compliance in church elections)