Steinar Myhre v. Seventh-Day Adventist Church Reform Movement American Union International Missionary Society, 719 F. App’x 926

Steinar Myhre, a former minister, alleged the American Union (subordinate divisions of the International Missionary Society Seventh-Day Adventist Church) canceled his retirement benefits after he was defrocked and excommunicated.
Myhre claimed he met eligibility conditions in the human resource manual (including "member in good standing," 10 years' service, and retirement age) and began receiving benefits in 2009; benefits were cancelled in 2013.
He pleaded causes of action including breach of express and implied contract, breach of covenant of good faith and fair dealing (alleging procedural violations), fraud, conversion, conspiracy, and interference by the General Conference.
The American Union moved to dismiss for lack of subject-matter jurisdiction under Rule 12(b)(1), arguing adjudication would implicate ecclesiastical questions barred by the First Amendment.
The district court dismissed, finding Myhre’s claims required interpretation of church doctrine, membership status, and internal disciplinary procedures, and thus were non-justiciable.
The Eleventh Circuit affirmed, holding civil courts lack jurisdiction over purely ecclesiastical disputes and that neutral-principles review was unavailable because resolution would require doctrinal and polity inquiries.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Justiciability / First Amendment	Myhre: courts can adjudicate contract and tort claims for benefits despite religious context.	American Union: adjudication would require interpreting church doctrine, membership and discipline, triggering First Amendment abstention.	Dismissed for lack of jurisdiction; First Amendment bars resolving ecclesiastical disputes.
Breach of contract (entitlement to benefits)	Myhre: he satisfied eligibility terms and thus American Union breached express/implied contracts by stopping benefits.	American Union: determining entitlement requires defining "member in good standing" and reviewing ecclesiastical rules.	Non-justiciable; contract claims depend on ecclesiastical determinations.
Fraud / fraud exception to ecclesiastical abstention	Myhre: fraud claims (e.g., false promise to pay) permit secular review.	American Union: alleged fraud would still require examining religious governance and doctrine beyond marginal review.	Fraud exception insufficient because resolution would demand doctrinal inquiry.
Procedural fairness / covenant of good faith / conspiracy	Myhre: church violated its own procedures and colluded to deny him benefits, breaching covenant and civil statutes.	American Union: reviewing internal procedure compliance would impermissibly question ecclesiastical tribunals and doctrine.	Claims involve internal church governance and are barred from civil review.

Serbian E. Orthodox Diocese v. Milivojevich, 426 U.S. 696 (civil courts must accept hierarchical church tribunals' decisions and may not review internal ecclesiastical law or discipline)
Crowder v. S. Baptist Convention, 828 F.2d 718 (11th Cir. 1987) (civil adjudication of religious disputes implicates both Establishment and Free Exercise Clauses and risks entangling courts in doctrine)
Watson v. Jones, 80 U.S. 679 (1871) (civil courts must abstain from theological controversy, church discipline, and ecclesiastical government questions)
Jones v. Wolf, 443 U.S. 595 (1979) (civil courts may apply neutral principles of law that avoid doctrinal entanglement, but not when resolution requires doctrinal inquiry)
Simpson v. Wells Lamont Corp., 494 F.2d 490 (5th Cir. 1974) (affirming dismissal where civil review would intrude on church discipline and governance)
Houston v. Marod Supermarkets, Inc., 733 F.3d 1323 (11th Cir. 2013) (standard of review: dismissal for lack of jurisdiction reviewed de novo)