DOE v. THE FIRST PRESBYTERIAN CHURCH U.S.A. OF TULSA
2017 OK 15
| Okla. | 2017Background
- Plaintiff John Doe, not a member of FPS Tulsa, was baptized there by Miller on December 30, 2012.
- Plaintiff alleges promises of confidentiality were made and baptism/publication on the internet caused harm abroad.
- Plaintiff traveled to Syria and alleges kidnapping, torture, and threats tied to the baptism publication.
- Plaintiff asserted breach of contract, negligence, and outrage; Defendants moved to dismiss for lack of jurisdiction.
- Trial court denied the motion to dismiss; later, the court granted dismissal for lack of subject matter jurisdiction under church autonomy.
- Oklahoma Supreme Court affirmed, holding the church autonomy doctrine bars civil courts from reviewing the baptism-publication dispute.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Does church autonomy bar jurisdiction here? | Doe contends civil courts may adjudicate tort/contract claims arising from publication. | FPS Tulsa argues ecclesiastical matters and church autonomy shield the dispute. | Yes; church autonomy bars jurisdiction. |
| Is publication of baptism on the internet an ecclesiastical act rooted in religious belief? | Doe argues publication separate from baptism itself and not protected. | Publication related to the sacrament and church doctrine, thus protected. | Publication is rooted in ecclesiastical doctrine; barred. |
| Did Doe consent to ecclesiastical jurisdiction by baptism? | Doe did not consent as a member; jurisdiction should not attach. | Baptism consented him to church regulation despite not becoming a member. | Consent to ecclesiastical jurisdiction exists via baptism; court lacks jurisdiction. |
| Can Guinn/Hadnot exemptions override in this atypical baptism context? | Older tort exceptions apply; not an internal discipline issue. | Recent precedent and Bryce/GUIN framework support autonomy here. | Autonomy governs; claims barred. |
Key Cases Cited
- Kedroff v. St. Nicholas Cathedral, 344 U.S. 94 (1952) (recognizes church autonomy and protection from secular control)
- Watson v. Jones, 80 U.S. 679 (1871) (ecclesiastical tribunals' decisions binding in religious matters)
- Guinn v. Church of Christ of Collinsville, 775 P.2d 766 (Okla. 1989) (limits on tort claims arising from ecclesiastical discipline)
- Hadnot v. Shaw, 826 P.2d 978 (Okla. 1992) (church discipline immune from civil scrutiny; but scope limited to membership context)
- Bryce v. Episcopal Church in the Diocese of Colorado, 289 F.3d 648 (10th Cir. 2002) (threshold question: whether misconduct is rooted in religious belief)
- Serbian Eastern Orthodox Diocese v. Milivojevich, 426 U.S. 696 (1976) (limits on secular review of internal church controversies)
- Bladen v. First Presbyterian Church of Sallisaw, 857 P.2d 789 (Okla. 1993) (recognizes limited dockering of tort claims in ecclesiastical contexts)
- Hosanna-Tabor Evangelical Lutheran Church and School v. E.E.O.C., 132 S. Ct. 694 (2012) (religious autonomy extends to ministerial employment decisions)