Presbyterian Church (U.S.A.) v. Edwards, 566 S.W.3d 175

Reverend Eric Hoey was hired by the Presbyterian Ministry Agency (PMA) as Director of Evangelism and Church Growth; he and others incorporated an outside entity and transferred church grant funds without authorization (funds were later returned).
The Church disciplined Hoey, reported the discipline to his Presbytery, and publicly disclosed general information about the incorporation and dissolution to the denomination.
Hoey was placed on administrative leave, then terminated; he sued in Jefferson Circuit Court for defamation based on the Church's statements that he "committed ethical violations."
The Church moved for summary judgment asserting ecclesiastical abstention/ministerial-exception (immunity) and asked the trial court to limit discovery pending an immunity ruling. The trial court ordered broad discovery.
The Church petitioned the Court of Appeals for a writ to prohibit broad discovery and to dismiss the action on immunity grounds; the Court of Appeals granted the writ in part (limited discovery to immunity-related matters) but declined to decide immunity on the merits.
The Supreme Court of Kentucky affirmed the Court of Appeals: it prohibited broad discovery unrelated to immunity but declined to resolve the immunity question now, leaving immunity fact-resolution to the trial court and any immediate appeal of an adverse immunity ruling.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court may compel broad, merits-based discovery before ruling on ecclesiastical-immunity/ministerial-exception defenses	Hoey argued discovery should proceed so he can develop proof of falsity and damages for his defamation claim	Church argued immunity protects it from the burdens of broad-reaching discovery until the threshold immunity issue is resolved	Court held that broad discovery into merits must be stayed until the trial court decides immunity; discovery may proceed narrowly on immunity-related issues only
Whether the Supreme Court should decide on the church's ecclesiastical-immunity/ministerial-exception claim now (via extraordinary writ)	Hoey implicitly urged proceeding in trial court; Court of Appeals declined to decide immunity	Church sought immediate writ to dismiss the suit on immunity grounds	Court declined to decide immunity now: immunity is a question of law for the trial court after factual development; adverse immunity rulings are immediately appealable

Hoskins v. Maricle, 150 S.W.3d 1 (Ky. 2004) (standard for extraordinary writs)
St. Joseph Catholic Orphan Soc'y v. Edwards, 449 S.W.3d 727 (Ky. 2014) (ecclesiastical-abstention compared to qualified immunity procedures)
Kirby v. Lexington Theological Seminary, 426 S.W.3d 597 (Ky. 2014) (limits on secular review and courts' control of discovery to avoid ecclesiastical entanglement)
Bender v. Eaton, 343 S.W.2d 799 (Ky. 1961) (extraordinary writs and irreparable harm discussion; certain special-cases exception)
Lexington-Fayette Urban Cty. Gov't v. Smolcic, 142 S.W.3d 128 (Ky. 2004) (immunity includes protection from burdens of litigation and discovery)
Rowan Cty. v. Sloas, 201 S.W.3d 469 (Ky. 2006) (party entitled to immunity is immune from burdens of defending the action)
Hosanna-Tabor Evangelical Lutheran Church & Sch. v. E.E.O.C., 565 U.S. 171 (U.S. 2012) (ministerial exception and church autonomy from secular review of minister employment)
Norton Hosps., Inc. v. Peyton, 381 S.W.3d 286 (Ky. 2012) (immunity involves material facts but is a question of law to be decided by the trial court)
Breathitt Cty. Bd. of Educ. v. Prater, 292 S.W.3d 883 (Ky. 2009) (order denying absolute-immunity claim is immediately appealable)