Key point 9-07. The First Amendment allows civil courts to resolve internal church disputes so long as they can do so without interpreting doctrine or polity.
A Michigan court ruled that it was barred by the "ecclesiastical abstention" doctrine from resolving a claim that a church school committed unlawful discrimination in denying a disabled student admission. An adolescent female (the "plaintiff") attended seventh and eighth grades at a church-affiliated private school. She claimed that she had been assured by school personnel that if she enrolled at the school for seventh and eighth grade, she would be guaranteed placement in ninth grade. However, plaintiff was denied admission to ninth grade. Some two months after being denied admission, the plaintiff was diagnosed with certain learning disabilities. Thereafter, the plaintiff sued the school for discriminating against her based on her disability. She alleged that despite being "long aware that she had a learning disability," the school denied her admission to ninth grade and "consistently relied upon her learning disability as a justification" for doing so.
The school argued that the civil courts lack subject-matter jurisdiction over this claim pursuant to the protections of the First Amendment. The trial court disagreed, and the school appealed. The appeals court observed: "It is well settled that courts, both federal and state, are severely circumscribed by the [First Amendment guarantee of religious freedom] in the resolution of disputes between a church and its members," and that "whenever the court must stray into questions of religious doctrine or ecclesiastical polity the court loses jurisdiction … . This limitation on civil court jurisdiction is referred to as the 'ecclesiastical abstention doctrine.'"