Jennison, Raymond v. Prasifka, Jeanette, 391 S.W.3d 660

Jennison filed suit in June 2010 against Prasifka, a parishioner, claiming slander, tortious interference with a contractual relationship, and wrongful discharge.
Jennison is a bi-vocational priest and stockbroker who entered a 2008 contract to serve as a priest at Saint David’s in Garland, Texas.
Prasifka allegedly complained to the Dallas Diocese and Bishop Stanton placed Jennison on inactive status after related inquiries.
A Diocese-presentment and disciplined proceedings were filed against Jennison, including a deposition and a Notice of Deposition
Prasifka moved to dismiss and pleaded jurisdiction on ecclesiastical abstention grounds; the trial court dismissed with prejudice; Jennison appeals to reverse.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ecclesiastical abstention deprives jurisdiction over claims	Jennison argues abstention does not apply since Prasifka isn’t a church officer and suit isn’t against the Church	Prasifka contends statements to the Diocese in church disciplinary context invoke ecclesiastical governance	Yes; abstention applies and court lacks jurisdiction

Serbian E. Orthodox Diocese v. Milivojevich, 426 U.S. 696 (1976) (ecclesiastical matters immune from civil review)
Patton v. Jones, 212 S.W.3d 541 (Tex. App.—Austin 2005) (precludes secular review of church disciplinary processes)
Westbrook v. Penley, 231 S.W.3d 389 (Tex. 2007) (church governance internal affairs protected by First Amendment)
Dean v. Alford, 994 S.W.2d 392 (Tex. App.—Fort Worth 1999) (ecclesiastical matters not subject to civil adjudication)
McClure v. Salvation Army, 460 F.2d 553 (5th Cir. 1972) (relationship between church and ministers is ecclesiastical core)
Williams v. Gleason, 26 S.W.3d 54 (Tex. App.—Houston [14th Dist.] 2000) (disciplinary actions linked to church governance invoke abstention)
Pleasant Glade Assembly of God v. Schubert, 264 S.W.3d 1 (Tex. 2008) (dismissing ecclesiastical dispute for want of jurisdiction)