Bibiji Kaur Puri v. Sopurkh Kaur Khalsa, 2017 U.S. App. LEXIS 266

Background

Yogi Bhajan led Sikh Dharma and created a network of entities (SSSSD, SSSC, Unto Infinity LLC (UI), and Sikh Dharma International (SDI)); SSSC and UI had governing documents requiring board members be "qualified as a minister of Sikh Dharma."
Plaintiffs are Yogi Bhajan’s widow and three children; they allege he designated them to succeed to board positions, but after his 2004 death defendants excluded them and converted assets.
Plaintiffs sued seeking declarations appointing them to the SSSC trusteeship and UI manager position and damages for lost compensation; defendants moved to dismiss under Rule 12(b)(6).
District court dismissed with prejudice, holding plaintiffs’ claims barred by the Free Exercise and Establishment Clauses (ministerial-exception/ecclesiastical-abstention doctrines). Plaintiffs appealed.
On review of the pleadings, the Ninth Circuit assumed defendants could assert the ministerial exception but held the complaint did not on its face establish the exception; the court further held the dispute is amenable to resolution under neutral principles of law rather than ecclesiastical abstention.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the ministerial exception bars the suit	Puri: board seats are secular governance positions, not ministerial employment	Defs: board seats require ministerial status and thus are protected by the ministerial exception	Court: On pleadings, not apparent seats are ministerial; exception not established at dismissal stage
Whether ecclesiastical abstention prevents secular adjudication	Puri: dispute can be decided by neutral application of state corporate and trust law	Defs: civil adjudication would intrude on church autonomy and doctrine	Court: Neutral-principles approach applicable; courts may decide factual/corporate questions without resolving doctrine
Whether neutral-principles approach is constitutionally available	Puri: Oregon law and corporate documents resolve ownership/appointment questions	Defs: Watson deference or other ecclesiastical approaches should control	Court: Prefer neutral principles in federal cases; application here does not require deciding doctrinal issues
Whether the complaint pleads fraud/collusion to overcome abstention	Puri: N/A at pleading stage	Defs: N/A	Court: No need to reach fraud/collusion exception because abstention not compelled on pleadings

Key Cases Cited

Hosanna-Tabor Evangelical Lutheran Church & Sch. v. EEOC, 132 S. Ct. 694 (2012) (recognizing the ministerial exception protecting a religious group’s choice of ministers)
Jones v. Wolf, 443 U.S. 595 (1979) (approving the neutral-principles-of-law approach for church property disputes)
Presbyterian Church in U.S. v. Mary Elizabeth Blue Hull Mem’l Presbyterian Church, 393 U.S. 440 (1969) (discussing limits on civil-court resolution of church disputes and introducing neutral principles concept)
Milivojevich, Serbian E. Orthodox Diocese v. Milivojevich, 426 U.S. 696 (1976) (ecclesiastical abstention; deference to highest ecclesiastical authority on doctrinal questions)
Bollard v. California Province of the Society of Jesus, 196 F.3d 940 (9th Cir. 1999) (ministerial-exception framework and limits on court intrusion into church decisions)
Elvig v. Calvin Presbyterian Church, 375 F.3d 951 (9th Cir. 2004) (ministerial-exception application and discussion of secular adjudication where possible)
Alcazar v. Corporation of the Catholic Archbishop of Seattle, 627 F.3d 1288 (9th Cir. 2010) (declining a bright-line test for ministerial status)
Kianfar, Maktab Tarighe Oveyssi Shah Maghsoudi, Inc. v. Kianfar, 179 F.3d 1244 (9th Cir. 1999) (applying neutral principles to church-affiliated corporate disputes)
Kedroff v. Saint Nicholas Cathedral, 344 U.S. 94 (1952) (federal protection for a church’s freedom to select clergy)
Gonzalez v. Roman Catholic Archbishop of Manila, 280 U.S. 1 (1929) (early recognition of church autonomy in clerical appointments)