Gregorio v. Hoover
238 F. Supp. 3d 37
| D.D.C. | 2017Background
- In 1995 Newton Gregorio and his wife founded Capital Wesleyan Church ("Capital"); Capital affiliated with the Wesleyan Church/Chesapeake District but allegedly retained organizational independence.
- Chesapeake obtained WIF loans to buy 3831 and 3829 14th St.; Chesapeake holds title to both deeds while Capital allegedly repaid the loans (3831 fully by 2005) and paid the promissory note on 3829 under a "special arrangement."
- Gregorio alleges an agreement that Chesapeake would hold title while loans were repaid and convey title to Capital once repaid; Chesapeake refused to convey 3831 after repayment.
- Gregorio served as Pastor/Minister in Charge (formally appointed by Superintendent Stanley Hoover), received a $1,500 monthly stipend until October 2012, and alleges Chesapeake stopped payments thereafter.
- In mid-2015 Hoover told Gregorio to retire; Chesapeake changed locks on the properties and sent letters to law enforcement alleging Gregorio made illegal entries.
- Gregorio sued (breach of contract, unjust enrichment, wrongful eviction, defamation, age discrimination, lost wages) against Chesapeake and Hoover; defendants moved to dismiss; court granted in part and denied in part.
Issues
| Issue | Gregorio's Argument | Chesapeake/Hoover's Argument | Held |
|---|---|---|---|
| Age discrimination | Hoover forced retirement because Gregorio was "old"; claim should proceed | Claim requires administrative exhaustion under ADEA/DCHRA; alternatively barred by ministerial exception | Claim abandoned by plaintiff; dismissed |
| Breach re: stipend (loss of wages) | Defendants promised $1,500/mo and breached when payments stopped Oct 2012 | Ministerial exception bars employment claims; promise likely by Capital not Chesapeake | Treated as breach of contract; ministerial exception premature at pleading stage; claim survives |
| Breach re: 3831 property conveyance | Agreement required Chesapeake to convey title to Capital after loan repayment; Chesapeake breached by retaining title | Ecclesiastical abstention/ministerial entanglement; deed and "Discipline" control and would require judicial inquiry into doctrine; statute of frauds/writing required | Court may adjudicate under neutral-principles approach; dismissal premature; breach of contract claim survives |
| Unjust enrichment (3831 & 3829) | Chesapeake unjustly retained benefit: title to 3831 despite Capital repaying loan; Capital paid 3829 loan too | Same jurisdictional/entanglement arguments; for 3829 retention was not unjust because arrangement contemplated Chesapeake ownership/use | Unjust enrichment claim regarding 3831 survives; unjust enrichment re: 3829 dismissed |
| Wrongful eviction | Changing locks deprived Gregorio/Capital of use/control; eviction was self-help and wrongful | Gregorio lacks lease/tenancy or ownership | Pleading suffices at this stage; tenancy or "something less" may exist; claim survives |
| Defamation | Letter to law enforcement falsely accused Gregorio of illegal entry; circulated with ill will | Qualified privilege for reports to police; truth defense | Court finds malice (ill will) plausibly alleged; privilege overcome at pleading stage; claim survives |
| Personal liability of Hoover | Hoover personally participated in decisions (appointment, lock change, letters) | Allegations are too generalized; no specific Hoover acts alleged | Generalized allegations adequate to survive pleading stage; claims against Hoover in his individual capacity survive |
Key Cases Cited
- Hosanna-Tabor Evangelical Lutheran Church & Sch. v. EEOC, 565 U.S. 171 (Sup. Ct.) (establishes ministerial exception to employment discrimination claims)
- Jones v. Wolf, 443 U.S. 595 (Sup. Ct.) (approves neutral-principles approach for church property disputes)
- Minker v. Baltimore Annual Conference of United Methodist Church, 894 F.2d 1354 (D.C. Cir.) (contract claims by ministers may proceed if resolvable by neutral methods)
- EEOC v. Catholic Univ. of Am., 83 F.3d 455 (D.C. Cir.) (discusses judicial limits under ecclesiastical abstention)
- Ashcroft v. Iqbal, 556 U.S. 662 (Sup. Ct.) (pleading standard: plausibility requirement)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (Sup. Ct.) (pleading standard guidance)