966 F.3d 346
5th Cir.2020Background
- Plaintiff Will McRaney, former Executive Director of the Baptist Convention for Maryland/Delaware (BCMD), sued the North American Mission Board of the Southern Baptist Convention (NAMB) for intentional interference with business relations, defamation, and intentional infliction of emotional distress.
- NAMB is a separate SBC agency and never McRaney’s employer; NAMB and BCMD had a Strategic Partnership Agreement (SPA) covering personnel and funding.
- McRaney refused to adopt a new SPA on behalf of BCMD; NAMB notified BCMD it would terminate the SPA in one year, and McRaney’s employment thereafter ended (resignation or termination).
- After his departure, McRaney alleges NAMB falsely told BCMD he refused to meet with NAMB’s president (Kevin Ezell), got him uninvited from a mission symposium, and posted his photo at NAMB headquarters to brand him untrustworthy.
- The district court dismissed for lack of jurisdiction under the ecclesiastical abstention (religious autonomy) doctrine, concluding resolution would require deciding ecclesiastical questions.
- The Fifth Circuit reversed and remanded, holding dismissal was premature because the complaint, as pled, raised neutral tort claims that may be resolvable under secular, neutral principles of law without deciding doctrinal or church-governance questions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ecclesiastical abstention bars McRaney’s tort claims | McRaney: claims are secular torts (defamation, interference, IIED) and can be decided by neutral principles | NAMB: adjudication may require resolving religious reasons and church-governance matters, so courts must abstain | Reversed dismissal — not certain at this stage that ecclesiastical questions are required; dismissal was premature |
| Whether adjudication would impermissibly entangle court in faith or doctrine | McRaney: no doctrinal or qualification issues are pleaded; dispute is about false secular statements | NAMB: may have valid religious reasons for actions that could implicate church matters | Court: factual development may reveal entanglement, but current record does not; district court may revisit after development |
| Whether ministerial exception or related defenses preclude suit | McRaney: ministerial exception not argued to apply here; this is a suit against a third party | NAMB: previously asserted ministerial exception and religious defenses generally | Circuit did not decide ministerial exception here; parties agreed correctness of district court’s prior ruling on that exception not before court |
| Proper procedural disposition (jurisdictional bar vs. merits dismissal) | McRaney: dismissal inappropriate on present record | NAMB: dismissal appropriate if ecclesiastical abstention applies | Court: decline to resolve doctrinal jurisdictional/defense distinction; regardless, dismissal was improper on available record |
Key Cases Cited
- Serbian E. Orthodox Diocese for U.S. and Can. v. Milivojevich, 426 U.S. 696 (1976) (First Amendment precludes judicial resolution of strictly ecclesiastical questions)
- Watson v. Jones, 80 U.S. 679 (1871) (civil courts lack jurisdiction over matters strictly ecclesiastical in character)
- Kedroff v. St. Nicholas Cathedral of Russian Orthodox Church in N. Am., 344 U.S. 94 (1952) (protecting church decisions on government, faith, and doctrine)
- Jones v. Wolf, 443 U.S. 595 (1979) (courts may apply neutral principles of law to church-related disputes without addressing doctrine)
- Hosanna-Tabor Evangelical Lutheran Church & Sch. v. EEOC, 565 U.S. 171 (2012) (ministerial exception bars certain employment claims implicating internal religious decisions)
- Our Lady of Guadalupe School v. Morrissey-Berru, 140 S. Ct. 2049 (2020) (First Amendment protects religious institutions’ decisions about matters of church government and doctrine)
- Drevlow v. Lutheran Church—Missouri Synod, 991 F.2d 468 (8th Cir. 1993) (denial of dismissal where alleged false secular information did not on its face require religious interpretation)
- Marshall v. Munro, 845 P.2d 424 (Alaska 1993) (state court retained jurisdiction over defamation and interference claims by minister where alleged statements were secular)
- Sanders v. Casa View Baptist Church, 134 F.3d 331 (5th Cir. 1998) (First Amendment does not categorically insulate religious relationships from neutral judicial scrutiny)
- Cannata v. Catholic Diocese of Austin, 700 F.3d 169 (5th Cir. 2012) (discussing standards of review applicable to Rule 12(b)(6) and 12(b)(1) dismissals)