Harpinder Singh, Jagjit S. Gill, and Baldev Singh v. Gurnam Singh Sandhar, Inqlabi Thandi, Daljit Singh, Baljinder Singh Bhatti, Sodagar Singh Virk, and Baljinder Singh
14-15-00087-CV
| Tex. App. | Oct 8, 2015Background
- Dispute over voting membership and leadership election at Gurudwara Sahib of Houston after 2012 applications would have more than doubled membership; by-laws require unanimous Prabandhak Committee (PC) approval for new voting members.
- Competing factions on the PC bypassed a general election, leading the court to order an election per the by-laws and to defer unresolved membership disputes to the Temple’s High Priest (Akal Takht).
- High Priest Saranjeet (Akal Takht) issued a "High Priest Approved Membership List" used in the court-ordered election; another group conducted a competing election and later was held in contempt for violating court orders (including improperly firing the High Priest).
- Appellants (some excluded applicants) sued seeking reinstatement as voting members, voiding the prior election, and ordering a new election so they could vote; they asserted various causes of action (fraud, breach, tortious interference, etc.).
- Defendants moved for summary judgment arguing the court lacked subject-matter jurisdiction under the First Amendment (Establishment Clause) and the Ecclesiastical Abstention Doctrine; the trial court granted summary judgment and deferred membership disputes to the High Priest.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the court had subject-matter jurisdiction over church membership/election disputes | Court can adjudicate alleged civil wrongs (fraud, breach) and order reinstatement of members | First Amendment and Ecclesiastical Abstention bar courts from resolving internal church membership/governance disputes | Court lacks jurisdiction; membership disputes are ecclesiastical and nonjusticiable |
| Whether courts may enforce bylaws or order specific membership reinstatement | Appellants: remedies for alleged bylaw violations and fraud include reinstatement and new election | Defendants: even neutral-principles review cannot reach questions of who may be members; relief would improperly interfere with religion | Enforcement of bylaws as contract is permissible only to an extent; ordering who is member is impermissible; relief sought denied |
| Whether the trial court properly deferred dispute to the Temple's highest authority (High Priest) | Appellants: dispute resolution should not defer to High Priest or priest lacked authority | Defendants: bylaws and precedent require deferral to highest ecclesiastical authority; parties had stipulated to Akal Takht | Court properly deferred to High Priest (Akal Takht) as ecclesiastical decisionmaker |
| Do pleaded tort and statutory claims (fraud, conspiracy, tortious interference) overcome Ecclesiastical Abstention | Appellants: civil claims are neutral and actionable | Defendants: tort claims are still ecclesiastical in substance here and do not pose public-safety exception; thus nonjusticiable | Claims dismissed; substance/effect of relief sought is ecclesiastical so abstention applies |
Key Cases Cited
- C.L. Westbrook, Jr. v. Penley, 231 S.W.3d 389 (Tex. 2007) (courts lack power to decide internal church membership and governance questions)
- Masterson v. Diocese of Nw. Texas, 422 S.W.3d 594 (Tex. 2013) (courts must defer ecclesiastical questions to appropriate ecclesiastical decisionmakers)
- Turner v. Church of Jesus Christ of Latter–Day Saints, 18 S.W.3d 877 (Tex. App.—Dallas 2000) (decisions revoking internal religious privileges are nonjusticiable)
- Retta v. Mekonen, 338 S.W.3d 72 (Tex. App.—Dallas 2011) (alleged bylaw violations on internal governance are ecclesiastical and nonjusticiable)
- Dean v. Alford, 994 S.W.2d 392 (Tex. App.—Fort Worth 1999) (courts should defer to highest church authority on nonjusticiable matters)
- Klouda v. Sw. Baptist Theological Seminary, 543 F. Supp. 2d 594 (N.D. Tex. 2008) (federal court applied ecclesiastical abstention to employment/termination-related claims involving religious institution)