Michigan Court Dismisses Minister’s Breach of Contract Suit

Courts not allowed to get involved in disputes involving ecclesiastical rule.

Church Law and Tax 1993-01-01 Recent Developments

Clergy – Removal

A federal court in Michigan ruled that the first amendment prevents the civil courts from reviewing the validity of a religious denomination’s dismissal of a minister. A Seventh Day Adventist minister was dismissed by a regional denominational committee. He sued his denomination (the “Church”), alleging breach of contract and intentional infliction of emotional distress. The court granted the Church’s request to dismiss the case. The court began its opinion by quoting Acts 18:15: “But if it be a question of words and names, and of your law, look ye to it; for I will be no judge of such matters.” It then observed: “It is without question that the executive committee had the authority to terminate [the minister’s] employment as a minister. In order to determine whether or not the committee followed its own rules and procedures in discharging the [minister], the court would be involved in an inquiry into questions of ecclesiastical rule, custom, and law. [The minister does] not allege fraud or collusion. Consequently, the free exercise clause of the first amendment bars this court’s further inquiry into this case.” The court quoted with approval from a federal appeals court decision in Hutchinson v. Thomas, 789 F.2d 392 (6th Cir. 1986): “This case involves the fundamental question of who will preach from the pulpit of a church, and who will occupy the church parsonage. The bar statement of the question should make obvious the lack of jurisdiction of a civil court. The answer to that question must come from the church.” Lewis v. Lake Region Conference of Seventh Day Adventists, 779 F. Supp. 72 (E.D. Mich. 1991).

See Also: Termination

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