“Church Autonomy” Applies in Church Name Dispute

Court 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.

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.

A state appeals court began its opinion with a description of the ecclesiastical abstention doctrine:

The ecclesiastical abstention doctrine is derived from the Religion Clauses of the First Amendment to the United States Constitution. Its purpose is to prevent the civil courts from engaging in unwarranted interference with the practices, internal affairs, and management of religious organizations. The ecclesiastical abstention doctrine prohibits secular courts from redetermining the correctness of a decision by a religious tribunal on issues of canon law, religious doctrine, or church governance. . . .

Because of the freedom of religion guaranteed in the Constitution, religious organizations may establish their own rules and regulations for internal discipline and government and create tribunals for adjudicating disputes over these matters. When this choice is exercised, the Constitution requires that civil courts accept such tribunals’ decisions as binding. Decisions of the highest church tribunal are binding on civil courts in all cases of ecclesiastical cognizance. Claims that a religious tribunal or organization violated its own rules are not reviewable by courts.

When the ecclesiastical abstention doctrine applies, it functions as a jurisdictional bar that precludes civil courts from adjudicating disputes that are strictly and purely ecclesiastical in character and which concern theological controversy, church discipline, ecclesiastical government, or the conformity of the members of the church to the standard of morals required by them. . . . Because it is a bar to jurisdiction, the ecclesiastical abstention doctrine may be raised at any time as a basis for dismissal of the lawsuit.

The court added that while the ecclesiastical abstention doctrine precludes courts from adjudicating most questions arising from church activities, “it does not apply in every legal dispute regarding religious organizations.” For example, courts may address claims involving religious organizations “as long as they can do so using neutral principles of law and can refrain from resolving religious disputes and from relying on religious doctrine.” In other words, if the trial court could have adjudicated the dispute “without resolving questions of religious doctrine, polity, or practice,” the ecclesiastical abstention doctrine would not bar its jurisdiction. However, if the issue involves resolution of such questions, the ecclesiastical abstention doctrine “would function as a jurisdictional bar precluding the trial court’s resolution of this matter.”

The court noted that the plaintiff’s lawsuit alleges that nonmembers were allowed to vote on the church’s name change, which rendered the vote illegal and void under the church’s bylaws. The bylaws explain how an individual may become a member of the church:

Any natural person may become a member of the corporation at any regular church service by . . . trusting Jesus Christ as his or her personal Savior and Lord and making a public statement of this trust through the witness of believer’s baptism . . . and by a personal statement which includes: his or her salvation experience in Christ, subsequent witness through believer’s baptism . . . requesting membership and agreeing to conform to the rules and regulations as may from time to time be established by a majority vote of the members.

The court concluded that “by its plain language,” the requirements for membership are rooted in the religious doctrines and practices of the church:

The [main argument] in the plaintiff’s complaint is whether the votes on the church’s name change were cast by members. As set out above, membership requires compliance with religious doctrine and practice. As such, questions of membership are not within the purview of the court by operation of the ecclesiastical abstention doctrine. Furthermore, a church’s decision to change its name is a decision regarding the internal affairs and management of the church and is a decision in which civil courts are prevented from interfering. Additionally, a claim that a church violated its own rules is not reviewable by courts. For these reasons, the ecclesiastical abstention doctrine functions as a bar to the court’s jurisdiction and the trial court did not err in granting summary judgment in favor of the church.

What this means for churches

This case is an excellent example of the impact of the ecclesiastical abstention doctrine (sometimes called the “church autonomy” doctrine) on church disputes. Internal church disputes that concern “theological controversy, church discipline, ecclesiastical government, or the conformity of the members of the church to the standard of morals required of them” are beyond the reach of the civil courts, and cannot be revived by appeals to “neutral principles of law.” Gunn v. First Baptist Church, 2018 WL 2749639 (Tenn. App. 2018).

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