Key point. Most courts regard a church's membership determinations to be a purely ecclesiastical matter beyond the review of the civil courts.
Key point. The civil courts will not resolve lawsuits brought by dismissed church members challenging the validity of their dismissal.
A Pennsylvania court ruled that it was barred by the first amendment from resolving a lawsuit by an individual who wanted to be admitted as a member of a church.
Besides seeking a court order compelling him to be admitted as a church member, the plaintiff also asked the court to remove the pastor and board as a result of their failure to use appropriate texts for worship in the Episcopal Church. A state appeals court upheld a trial court's dismissal of the case on the ground that it involved issues of ecclesiastical law and doctrine which the civil courts are powerless to resolve. It relied upon what it called the "deference rule":
This prohibition on civil courts from deciding issues of ecclesiastical law and religious doctrine, custom, policy and practice is referred to as the "deference rule." The deference rule provides that civil courts are bound to accept the decisions of the highest judicatories of a religious organization of hierarchical polity on matters of discipline, faith, internal organization, or ecclesiastical rule, custom or law.
The court also ordered the plaintiff to pay the church's attorney fees since the case was so lacking in merit. The court pointed out that the civil courts have consistently followed the deference rule, and that there was no legal precedent in support of the plaintiff's claims.
What this means for churches
This case illustrates the nearly universal view that the civil courts are barred by the first amendment from resolving internal church disputes involving discipline, faith, internal organization, or ecclesiastical rule, custom or law. Further, the case suggests that churches should consider demanding payment of their attorney's fees in the event they are forced to defend a lawsuit that is dismissed as a result of the deference rule. In re St. Clement's Church, 687 A.2d 11 (Pa. Common. 1996).
