Key point 6-12.4. Most courts refuse to intervene in church disputes concerning the validity of a membership meeting that was not conducted in accordance with the procedural requirements specified in the church’s governing documents. However, some courts are willing to intervene in such disputes if they can do so without inquiring into religious doctrine or polity.
A Tennessee court ruled that it was barred by the ecclesiastical abstention doctrine from resolving a church member’s lawsuit challenging the legal validity of a vote by church members to change the name of the church. In 2017 a church voted to change its name. A church member (the “plaintiff”) was upset with the new name, and filed a lawsuit against the church, pastor, and board of deacons, claiming that the vote to change the name was illegal and void. The plaintiff asked the trial court to set aside the vote, order a new vote, and enjoin the church from changing its name.
The church asked the court to dismiss the lawsuit on the ground that the “ecclesiastical abstention doctrine” deprived the court of jurisdiction over the case. The court agreed, finding that it did not have jurisdiction over the case because the ecclesiastical abstention doctrine precluded it from adjudicating any issue regarding the internal affairs and management of the church. The court explained that the plaintiff’s primary concern was whether each person who voted on the church’s name change was a member of the church. The court concluded that it did not have authority to determine whether each voter was a member of the church and, as a result could not resolve the plaintiff’s lawsuit. The plaintiff appealed.