A Michigan state appeals court held that it lacked jurisdiction to resolve the claims of parishioners that they had suffered intentional infliction of emotional distress as a result of their priest's actions.
Several parishioners withheld their financial support from the church because of their opposition to certain changes that a new priest had initiated. In response to this action, the priest refused to give communion to certain dissident members in the presence of the entire congregation, and verbally criticized others during services.
The court observed that "it is well settled that courts, both federal and state, are severely circumscribed by [the state and federal constitutions] in the resolution of disputes between a church and its members. Such jurisdiction is limited to property rights which can be resolved by application of civil law."
In rejecting the members claim that the church had intentionally caused them emotional distress, the court remarked: "This is quite a modern tort not yet recognized by the highest court in this state. Hopefully, it never will be. The awesome flood of litigation has already risen to the gunnels. If the courts were to offer to extract money from everyone who intentionally makes someone else mad, we would surely go under." Maciejewski v. Breitenbeck, 413 N.W.2d 65 (Mich. App. 1987)