Chad Speller v. Saint Stephen Lutheran Church of Drayton Plains, 330739

Plaintiff Chad Speller, an ordained LCMS minister, was senior pastor at Saint Stephen Lutheran Church and sued the church, a board member (Beebe), the Michigan District LCMS, and District President Maier after efforts to force his resignation and place him on “restricted status” on the LCMS synodical roster.
He filed an eight-count complaint alleging breach of contract, breach of fiduciary duty, multiple torts (defamation, false light, fraud, IIED), civil conspiracy, and concert of action, claiming damage to reputation and loss of ability to minister.
Defendants moved for summary disposition under MCR 2.116(C)(4) (lack of subject-matter jurisdiction) and (C)(10) (no genuine issue of material fact), arguing judicial intervention would implicate ecclesiastical matters.
The trial court granted summary disposition, holding it lacked jurisdiction under the ecclesiastical abstention doctrine because resolution would require inquiry into church governance, discipline, and plaintiff’s employment as a minister.
The Court of Appeals affirmed, concluding the substance and effect of Speller’s claims required delving into internal church polity and decisions about clergy employment, which are constitutionally protected from civil-court review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court had subject-matter jurisdiction over Speller’s claims	Speller: claims can be resolved under neutral principles of law without resolving ecclesiastical doctrine or polity	Defendants: First Amendment bars civil courts from adjudicating internal church governance and clergy employment disputes	Held: No jurisdiction; ecclesiastical abstention bars review
Whether breach of contract claim (church constitution/bylaws) is justiciable	Speller: church constitution governs his employment; defendants breached protocol	Defendants: enforcing or interpreting church constitution requires ecclesiastical inquiry	Held: Dismissed — would require probing church polity
Whether tort claims (defamation, false light, fraud, IIED) are actionable	Speller: statements were false and caused reputational and economic harm; tort law applies neutrally	Defendants: statements were made in the context of internal church discipline and governance	Held: Dismissed — resolution would require assessing internal disciplinary decisions and clergy status
Whether conspiracy and concert-of-action claims survive absent the underlying torts	Speller: defendants conspired to force resignation and defame him	Defendants: claims rest on ecclesiastical matters and underlying torts are nonjusticiable	Held: Dismissed — derivative claims implicate ecclesiastical polity and lack jurisdiction

Hosanna-Tabor Evangelical Lutheran Church & Sch. v. EEOC, 565 U.S. 171 (2012) (First Amendment bars government review of certain ministerial employment decisions)
Pilgrim’s Rest Baptist Church v. Pearson, 310 Mich. App. 318 (2015) (Michigan application of ecclesiastical abstention; courts may decide secular property disputes but must avoid questions of doctrine and polity)
Hutchison v. Thomas, 789 F.2d 392 (6th Cir. 1986) (civil courts cannot review internal church government or discipline regarding clergy employment)
Lewis v. Seventh Day Adventists Lake Region Conf., 978 F.2d 940 (6th Cir. 1992) (First Amendment bars review of religious judicatory decisions about clergy employment, even when procedure is alleged to be misapplied)
Weishuhn v. Catholic Diocese of Lansing, 287 Mich. App. 211 (2010) (constitutional limits on state-court involvement in internal church matters)