Key point. According to the majority view, the civil courts will not resolve disputes challenging a church's discipline of a member since the First Amendment guaranty of religious freedom prevents them from deciding who are members in good standing of a church.

A Tennessee court ruled that it was barred by the First Amendment guaranty of religious freedom from resolving a church member's defamation claims against his pastor based on a letter that was read to the congregation. A man ("Owen") had attended the same church for 70 years and served as trustee for 30 years. Owen claimed that his pastor gave false information to an attorney about him, which the attorney placed in a letter that was sent to the pastor. The pastor read this letter to the entire congregation during a regular Sunday morning church service. While Owen was not identified as the subject of the letter at the reading, he believed that everyone knew the letter's remarks were about him. Owen later sued the pastor for defamation. The attorney's letter was attached to the lawsuit. The letter states, in relevant part: