DOE v. THE FIRST PRESBYTERIAN CHURCH U.S.A. OF TULSA
2017 OK 106
| Okla. | 2017Background
- Plaintiff John Doe, a Syrian-born nonmember who sought a private baptism at First Presbyterian Church (FPC), alleges the church promised confidentiality but published his baptism notice online, leading to his kidnapping and torture in Syria.
- Doe consented to baptism only after assurances of privacy; parties agree he never became a church member.
- After the church posted the baptism online, Doe was allegedly identified abroad by extremists, kidnapped, and harmed; he sued FPC and its minister for torts and breach of contract.
- The district court granted defendants' second motion to dismiss for lack of subject matter jurisdiction, concluding the dispute implicated ecclesiastical matters.
- The Oklahoma Supreme Court reviewed whether the church-autonomy doctrine deprives state courts of jurisdiction when factual disputes central to the claim exist and whether the motion should have been treated as a motion for summary judgment.
- The majority reversed and remanded, finding disputed factual issues (consent and what was promised) required resolution by the trier of fact and that church-autonomy is an affirmative defense not a jurisdictional bar in this context.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether church-autonomy (ecclesiastical abstention) deprives the court of subject matter jurisdiction | Doe: state courts retain jurisdiction because he never consented to church governance and his claims are secular (tort/breach) | FPC: publication of baptism is rooted in church doctrine; ecclesiastical questions bar secular inquiry | Held: court erred to dismiss for lack of jurisdiction; disputed facts about consent and promises convert jurisdictional inquiry into merits and require trial; remanded |
| Whether the motion to dismiss under 12(b)(1) should be converted to summary judgment because defendants submitted outside evidence | Doe: evidence goes to elements of his claims (consent/promise) so conversion appropriate and summary process premature due to disputes | FPC: submission of doctrinal materials properly used to show jurisdictional bar; conversion unnecessary | Held: because the outside evidence addressed contested elements of Doe's claims, the motion should have been treated as one for summary judgment; factual disputes preclude summary disposition |
| Role of membership/consent in applying church-autonomy | Doe: he never became a member and did not consent to be governed by FPC doctrine, so ecclesiastical protections don't apply | FPC: baptismal practices implicate ecclesiastical governance regardless of membership | Held: membership/consent is central; absence of consent undermines church-autonomy protection here and is a factual question to be resolved at trial |
| Status of ministerial exception vs. broader church-autonomy doctrine (jurisdictional or affirmative defense) | Doe: church-autonomy (like ministerial exception) should not strip courts of jurisdiction; it functions as an affirmative defense | FPC: relies on church-autonomy to assert jurisdictional bar | Held: majority follows U.S. Supreme Court guidance that such doctrines often operate as affirmative defenses (citing Hosanna-Tabor) and treats church-autonomy as not automatically depriving the court of jurisdiction in this case; factual entanglement required before applying the doctrine |
Key Cases Cited
- Watson v. Jones, 80 U.S. 679 (U.S. 1871) (foundational statement of ecclesiastical abstention and the role of consent/membership)
- Kedroff v. St. Nicholas Cathedral, 344 U.S. 94 (U.S. 1952) ( First Amendment protection for church governance and autonomy)
- Hosanna-Tabor Evangelical Lutheran Church & Sch. v. EEOC, 565 U.S. 171 (U.S. 2012) (ministerial-exception characterized as a merits defense rather than purely jurisdictional)
- Guinn v. Church of Christ of Collinsville, 775 P.2d 768 (Okla. 1989) (Oklahoma precedent limiting ecclesiastical protection to consenting members)
- Hadnot v. Shaw, 826 P.2d 978 (Okla. 1992) (membership status limits church's civil immunity for post-membership claims)
- Osage Nation v. Board of Commissioners of Osage County, 394 P.3d 1224 (Okla. 2017) (procedural guidance converting jurisdictional motions to summary-judgment when outside evidence addresses substantive elements)
- Bryce v. Episcopal Church in the Diocese of Colorado, 289 F.3d 648 (10th Cir. 2002) (church-autonomy doctrine can apply to claims involving nonmembers when entanglement with ecclesiastical matters exists)