Rymer v. Lemaster, 3:16-cv-02711

Background

Pro se plaintiff Lincoln Rymer sued multiple defendants alleging a long‑running conspiracy that used protected student data and a "flirty fishing" scheme to induce his conversion to Christianity and caused physical, psychological, and economic harms.
Defendant Roger Oldham, a Baptist minister, was alleged to have acted as a spiritual adviser who (among other things) recruited Rymer, made religious statements (including a warning that God would kill him if he turned from God), and used student information to tailor outreach.
Rymer asserted numerous federal and state causes of action (CFAA, RICO, §1981, Title IX, FERPA/PPRA-related theories, common‑law torts, breach of fiduciary duty, etc.) and sought treble, compensatory, punitive, and equitable relief.
Oldham moved to dismiss under Fed. R. Civ. P. 12(b)(1) and (6), arguing the claims necessarily require judicial inquiry into religious doctrine and are barred by the ecclesiastical‑abstention/First Amendment protections; he also contended Rymer’s allegations against him are conclusory.
Rymer opposed, arguing ecclesiastical abstention cannot be resolved on a Rule 12 motion, that Oldham’s speech included unprotected threats and fraud, and that many allegations are pleaded "on information and belief" but are sufficiently particular for a pro se plaintiff.
The magistrate judge recommended granting Oldham’s motion: the court lacks subject‑matter jurisdiction under the ecclesiastical abstention doctrine for claims rooted in the alleged wrongful conversion, and the remaining allegations against Oldham are conclusory and fail to state a claim.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether court has subject‑matter jurisdiction to adjudicate claims that require evaluating religious doctrine/acts (ecclesiastical abstention)	Rymer: this is not an "internal church dispute"; claims are secular torts and conspiracies using protected student data; abstention is improper at Rule 12 stage	Oldham: adjudication would require scrutinizing religious beliefs, statements, and conversion—impermissible under ecclesiastical abstention/First Amendment	Court: Dismissed those claims for lack of subject‑matter jurisdiction under ecclesiastical abstention
Whether Oldham’s asserted First Amendment protections fail because his speech included threats/false statements/unprotected conduct	Rymer: Oldham’s statements included death threats, fraudulent inducement, and reckless endangerment—unprotected speech and not immune	Oldham: His conduct was ministerial religious speech and protected; no physical coercion alleged	Court: Found the core claims turn on religious veracity and are barred by ecclesiastical abstention; Plaintiffs’ allegations of unprotected speech were insufficiently pleaded to overcome abstention
Whether Rymer pleaded actionable conspiracy, fiduciary duty, fraud, and other torts with sufficient factual specificity	Rymer: Many allegations are pleaded on information and belief and pro se status relaxes pleading requirements; claims can be amended	Oldham: Allegations are conclusory; fail to meet Twombly/Iqbal standards	Court: Found the non‑religious allegations against Oldham conclusory and insufficient to state a claim under Rule 12(b)(6)
Relief — whether Oldham should remain a defendant	Rymer: Requests leave to amend and contends dismissal improper	Oldham: Move to terminate as party after dismissal	Court: Recommended granting the motion, dismissing all claims against Oldham, and terminating him as a party

Key Cases Cited

Watson v. Jones, 80 U.S. 679 (1871) (establishes principle that civil courts must avoid entanglement in ecclesiastical matters)
Serbian E. Orthodox Diocese v. Milivojevich, 426 U.S. 696 (1976) (courts cannot second‑guess highest church judicatories on matters of doctrine and governance)
Presbyterian Church v. Hull Church, 393 U.S. 440 (1969) (civil courts lack ecclesiastical jurisdiction over religious disputes)
Lewis v. Seventh Day Adventists Lake Region Conference, 978 F.2d 940 (6th Cir. 1992) (First Amendment bars civil review of certain internal church decisions)
Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (2007) (complaint must plead facts plausibly suggesting entitlement to relief)
Ashcroft v. Iqbal, 556 U.S. 662 (2009) (legal conclusions unsupported by factual allegations are insufficient)
RMI Titanium Co. v. Westinghouse Elec. Corp., 78 F.3d 1125 (6th Cir. 1996) (distinguishes facial and factual attacks under Rule 12(b)(1))
Ohio Nat'l Life Ins. Co. v. United States, 922 F.2d 320 (6th Cir. 1990) (standards for facial v. factual jurisdictional attacks)
United States v. Ritchie, 15 F.3d 592 (6th Cir. 1994) (factual attack is challenge to the factual existence of jurisdiction)