Can a civil court determine which of two warring factions of church trustees rightfully holds office?
No, ruled a Pennsylvania appeals court. A minister in a local church had ousted several trustees from office, replacing them with new trustees more loyal to himself. The ousted trustees alleged that the minister lacked the authority to replace them, and that they accordingly were still the lawful church board.
The court, noting that civil courts must "defer" to churches and their own ecclesiastical organizations regarding any question of "discipline, faith, ecclesiastical rule, custom, or law," held that the question of a minister's authority to replace church trustees involves ecclesiastical law and therefore must be resolved by the church itself. It ordered the trial court to identify the highest body within the church empowered to decide the issue. Atterberry v. Smith, 522 A.2d 683 (Pa. App. 1987).