Civil Court Did Not Have the Authority to Resolve a Lawsuit Brought by a Former Minister Against Denominational Officials

Rev. McManus had served as an ordained minister in the Church of God (Cleveland, Tennessee)

Rev. McManus had served as an ordained minister in the Church of God (Cleveland, Tennessee) for more than 30 years. In 1977, he disciplined certain members of his congregation, who thereafter were accepted as members in a neighboring Church of God congregation. Rev. McManus protested the action of the neighboring church to the "state overseer" of the denomination, on the ground that denominational rules had been violated. Both the state overseer and the national denomination refused to support Rev. McManus.

Rev. McManus and his congregation "protested" these actions by withholding "tithes" to the national organization. As a result, Rev. McManus was removed from his position as "district overseer" and from a place on the editorial and publishing board of the Church of God denomination. He later ceased to be a minister with the Church of God, and sued denominational officials as well as the state and national offices of the Church of God, for defamation.

The Louisiana appeals court, in concluding that it lacked jurisdiction to resolve the dispute, relied upon a 1976 decision of the United States Supreme Court, which held that the United States Constitution "permits hierarchical religious organizations to establish their own rules and regulations for internal discipline and government, and to create tribunals for adjudicating disputes over these matters. When this choice is exercised and ecclesiastical tribunals are created to decide disputes over the government and direction of subordinate bodies, the Constitution requires that civil courts accept their decisions as binding upon them." Serbian Eastern Orthodox Diocese v. Milivojevich, 426 U.S. 696 (1976).

The Louisiana court concluded that "[i]t would be ludicrous to believe that the constitutional principles upheld by the United States Supreme Court … could be satisfied by allowing this intrusion into the disciplinary proceedings of an ecclesiastical board. To allow defamation suits to be litigated to the fullest extent against members of a religious board who are merely discharging the duty which has been entrusted to them by their church could have a potentially chilling effect on the performance of those duties." McManus v. Taylor, 521 So.2d 449 (La. App. 1988)

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