Key point 2-04.1. Most courts have concluded that they are barred by the First Amendment guarantees of religious freedom and nonestablishment of religion from resolving challenges by dismissed clergy to the legal validity of their dismissals.
An Indiana appeals court ruled that it was barred by the First Amendment from resolving a dispute between a church and former pastor over compensation and benefit issues, and rejected the pastor's claim that it could resolve the dispute through application of neutral principles of law requiring no recourse to church doctrine or polity. On October 17, 2010, a pastor (the "plaintiff") was "called" to be the pastor of a Presbyterian church in Indiana. On that date, the plaintiff entered into a contract that covered a three-year period beginning on October 18, 2010. The "Terms of Call" set forth in the contract provided that the pastor would receive a stated salary, housing, and other benefits, including five weeks of vacation.
In the summer of 2012, the relationship between the pastor and congregation began to deteriorate. The church maintained that the plaintiff alienated himself from the congregation when he "neglected his pastoral responsibilities" by failing to make himself available for pastoral counseling services, missing scheduled appointments with parishioners, and refusing to keep the church board ("session") informed of his whereabouts and activities even after being asked to do so. The church claimed that from June 2012 to July 2012, the pastor: (1) "abandoned" his pastoral duties and was absent from church, without informing the session or obtaining consent to take vacation time; and (2) repeatedly failed to provide pastoral services to the church and its members without explanation.
The pastor insisted that during the time frame in question he utilized two of the five weeks of vacation he was entitled to and that he informed the session in advance. He claimed that he did not abandon his congregation and identified his pastoral activities, which included meeting with congregation members, conducting a funeral, leading a worship service at a local retirement community, and volunteering at a soup kitchen.
The discord between pastor and congregation escalated to a point where a regional denominational agency (the "presbytery") intervened to meet with the pastor, the session, and congregation, in an effort to resolve the discord. The pastor walked out of the meeting and failed to meet further with the presbytery. Soon thereafter, the presbytery and its commission on mission decided that "the pastoral relationship between [the plaintiff and church] is no longer viable and needs to be ended in order to prevent further deterioration of the spiritual health of the church." The plaintiff was so informed by letter. The letter further provided that the presbytery and church would work with the plaintiff to negotiate a fair and equitable severance package, but the plaintiff declined the offer. On or about that same day, the presbytery notified the church and its session of its decision to dissolve the plaintiff's pastoral position.
The plaintiff sued the church, seeking compensation for unpaid salary and benefits, including unpaid vacation wages, to which he claimed he was entitled pursuant to the terms of call set out in his contract. The church filed an answer, seeking a determination that the plaintiff had breached his obligations and promises to the congregation by abandoning his pastoral duties. As such, the church argued that it was no longer obligated under the contract to compensate him for unused vacation time.
The trial court dismissed the case, concluding that resolving the dispute between the parties would require it "to interpret and apply religious doctrine or ecclesiastical law." The plaintiff appealed, arguing that his claims for compensation and benefits could be resolved without implicating doctrine or polity and so were not barred by the First Amendment. A state appeals court rejected the plaintiff's argument:
There is no doubt that the terms of call set forth in the contract provided that the pastor would receive five weeks of vacation. The question remains, however, as to whether upon the termination of his pastoral relationship by the presbytery he was still entitled to compensation for unused vacation time. This determination necessarily would have required inquiry into the reason for termination … . The church cited abandonment of his pastoral duties as the impetus for termination of the plaintiff's pastoral relationship … . The presbytery determined that the discord between the pastor and congregation resulting from the belief that the plaintiff abandoned his duties had reached the point where his pastoral relationship needed to end "in order to prevent further deterioration of the spiritual health of the church." The church therefore asserts that the plaintiff, having abandoned his position, breached the contract, thereby relieving it of any further obligations under the contract. The pastor denies abandoning his pastoral duties and lists his pastoral activities in the weeks leading up to his termination.
To address these competing positions regarding the facts of this case would require a court to inquire into the religious doctrine of the church and its polity. A court would have to determine what the duties of a pastor called to serve a local session and congregation entail and then decide whether the pastor's conduct met such standards. Essentially, the court would have to second-guess, in this case, the presbytery as to its determination that the plaintiff's pastoral relationship was detrimental to the spiritual health of the church. Indeed, the court's inquiry would require delving into church doctrine to pass judgment on whether plaintiff was fit to serve as pastor of the church and whether the pastoral services he claimed to have provided were sufficient to meet the standards set forth by the Presbyterian Church. It is in this vein that this court has held that the First Amendment "proscribes intervention by secular courts into any employment decision made by religious organizations based on religious doctrines or beliefs.
"We conclude that the trial court properly determined that review of the issues presented would have necessitated the court to interpret and apply religious doctrine or ecclesiastical law. The First Amendment requires civil courts to refrain from interfering in such matters. We therefore conclude that the trial court properly [dismissed the plaintiff's lawsuit]."
What This Means For Churches:
The importance of this case is the court's rejection of the argument that employment disputes between clergy and churches can be resolved by the civil courts so long as they can do so without reference to doctrine or polity. As this court noted, it is the rare exception for such disputes to be capable of resolution on strictly neutral principles without reference to doctrine or polity. Matthies v. First Presbyterian Church, 28 N.E.3d 1109 (Ind. 2015).