Greater Fairview Missionary Baptist Church v. Danny Ray Hollins, 160 So. 3d 223

Pastor Danny Ray Hollins was placed on paid administrative leave after a church member accused him of inappropriate sexual contact with a minor.
The Deacons’ Ministry, with outside counsel, prepared an election procedure and scheduled a congregational vote on March 2, 2013, to decide whether Hollins should remain pastor.
Hollins filed for a temporary restraining order (TRO) in chancery court the day before the vote alleging lack of certified voter rolls, inadequate notice, and failure to follow denominational conciliation procedures.
The chancellor issued a TRO (served on four deacons), but the church held the March 2 vote anyway and removed Hollins.
The chancery court later set aside the vote, ordered a new court-supervised vote with specified procedures, and ordered Hollins reinstated; defendants sought interlocutory review.
The Mississippi Supreme Court granted interlocutory appeal and reversed and vacated the chancery court’s TRO, vacatur of the vote, and order for a new vote.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Personal jurisdiction / service of process	Service on four deacons was insufficient to bind the church.	Service on four elected deacons who had authority (especially while pastor absent) properly effected service under Miss. R. Civ. P. 4(d)(4).	Service was proper; chancery court had personal jurisdiction.
Subject-matter jurisdiction to enjoin church ministerial decision	Court can order procedures or vacate defective congregational votes where bylaws/procedures are unclear (citing Pilgrim Rest).	Ministerial employment decisions are ecclesiastical and protected by the First Amendment; courts lack jurisdiction to decide pastor-termination disputes.	Chancery court lacked subject-matter jurisdiction under the ministerial exception; TRO and subsequent orders were void.
Applicability of Pilgrim Rest precedent	Pilgrim Rest authorizes limited court intervention to restore a status quo when internal procedures are lacking.	Pilgrim Rest is a narrow exception and does not permit civil courts to decide purely ecclesiastical disputes about a pastor’s termination.	Pilgrim Rest is narrow and distinguishable; it does not permit the chancery court’s intervention here.

Hosanna-Tabor Evangelical Lutheran Church and School v. E.E.O.C., 132 S. Ct. 694 (2012) (recognizes the ministerial exception: civil courts may not decide disputes concerning selection/termination of ministers).
Pilgrim Rest Missionary Baptist Church ex rel. Bd. of Deacons v. Wallace, 835 So. 2d 67 (Miss. 2003) (chancery court ordered new vote where church procedures were unclear; treated as a narrow exception).
In re Bell, 962 So. 2d 537 (Miss. 2007) (injunctive relief must be predicated on a cognizable legal or equitable claim with likelihood of success on the merits).
Sawyer v. Brandon, 825 So. 2d 26 (Miss. 2002) (civil courts will not control ecclesiastical decisions about church officers and ministers).