Bettina Winkler v. Marist Fathers of Detroit Inc
901 NW2d 566
Mich.2017Background
- Bettina Winkler attended the middle-school division of Notre Dame Preparatory & Marist Academy (NDPMA) but was denied admission to its high school; she sued under the Persons With Disabilities Civil Rights Act (PWDCRA), alleging denial due to dyslexia.
- Defendant (Marist Fathers of Detroit, Inc.) moved for summary disposition under MCR 2.116(C)(4) (lack of subject-matter jurisdiction) and (C)(10), arguing ecclesiastical abstention barred court review and that PWDCRA did not apply to religious schools; plaintiff sought a preliminary injunction.
- The trial court denied the (C)(4) motion, finding it had jurisdiction and that defendant’s stated reasons appeared secular; it declined to resolve (C)(10) as premature.
- The Court of Appeals reversed, relying on Dlaikan v. Roodbeen to hold ecclesiastical abstention deprived the court of subject-matter jurisdiction and ordered (C)(4) dismissal.
- The Michigan Supreme Court granted review and addressed whether ecclesiastical abstention is a jurisdictional bar or a case-specific limitation on adjudication.
- The Supreme Court unanimously held ecclesiastical abstention does not strip subject-matter jurisdiction; it overruled Dlaikan to the extent it held otherwise and remanded for further consideration of defendant’s non-jurisdictional defenses.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ecclesiastical abstention deprives state circuit courts of subject-matter jurisdiction over claims involving religious institutions | Winkler: Circuit courts have jurisdiction over PWDCRA claims; abstention governs how courts adjudicate, not whether they may hear the case | Marist: Ecclesiastical abstention (per Dlaikan) means courts lack subject-matter jurisdiction to review parochial school admission decisions | Court: Ecclesiastical abstention does not divest subject-matter jurisdiction; Dlaikan overruled to that extent |
| Whether adjudication of Winkler’s PWDCRA claim would impermissibly entangle the court in religious doctrine or polity | Winkler: The complaint alleges secular bases for denial (grades, test results); fact-specific inquiry required | Marist: Admission decisions are integral to religious mission; inquiry would intrude on ecclesiastical matters | Court: Whether adjudication would entangle the court is a case-specific question for the trial court to decide under the abstention doctrine, not a jurisdictional bar |
| Proper procedural vehicle for dismissal based on ecclesiastical concerns | Winkler: Dismissal on jurisdictional grounds (MCR 2.116(C)(4)) is improper when the issue is factual/entanglement-based | Marist: (Relied on C)(4) via Dlaikan) | Court: (C)(4) inappropriate; ecclesiastical abstention may be raised and considered, but dismissal must follow appropriate standards (not automatic C)(4) jurisdictional dismissal) |
| Whether the Court of Appeals should have reached other defenses (e.g., PWDCRA inapplicability) | Winkler: Court should proceed to consider merits and defenses on remand | Marist: Court of Appeals declined to address those defenses after finding jurisdictional bar | Court: Remanded to Court of Appeals to consider defendant’s argument that PWDCRA does not apply to its school and other non-jurisdictional defenses |
Key Cases Cited
- Dlaikan v. Roodbeen, 206 Mich. App. 591 (Mich. Ct. App.) (case holding ecclesiastical abstention deprived jurisdiction; overruled in part)
- Joy v. Two-Bit Corp., 287 Mich. 244 (Mich. 1939) (definition of subject-matter jurisdiction as class-based, not fact-based)
- Hosanna-Tabor Evangelical Lutheran Church & Sch. v. EEOC, 565 U.S. 171 (U.S. 2012) (ministerial exception grounded in First Amendment; not a jurisdictional bar)
- Jones v. Wolf, 443 U.S. 595 (U.S. 1979) (courts may not resolve church disputes on doctrinal grounds and must defer when appropriate)
- Presbyterian Church in the U.S. v. Mary Elizabeth Blue Hull Mem'l Presbyterian Church, 393 U.S. 440 (U.S. 1969) (civil courts can adjudicate church property disputes without violating First Amendment in many cases)
- Lamont Cmty. Church v. Lamont Christian Reformed Church, 285 Mich. App. 602 (Mich. Ct. App.) (recognizes ecclesiastical abstention as non-jurisdictional and requiring case-specific analysis)
- Travelers Ins. Co. v. Detroit Edison Co., 465 Mich. 185 (Mich. 2001) (subject-matter jurisdiction is not dependent on particular facts)