Can One Church Warn Another of a Former Employee's Misconduct?
Can One Church Warn Another of a Former Employee's Misconduct?
A negative employment reference could create civil liability.

If Church A dismisses an employee for misconduct and the former employee is hired by Church B, does Church A have a legal duty to warn Church B about the employees misconduct?

This article will review a recent case addressing this question, review several other cases, and conclude with a helpful checklist.

A recent case: McRaney v. Mission Board

In McRaney v. Mission Board, 304 F. Supp.3d 514 (N.D. Miss. 2018), a federal district court in Mississippi ruled that it was not barred by the ministerial exception or ecclesiastical abstention doctrine from resolving a case involving a minister’s claims against a denominational missions board.


A missions agency terminated the employment of its executive director (the “plaintiff”), an ordained minister. The plaintiff said an unrelated denominational missions board interfered with his business and contractual relationships with third parties, including the agency that fired him. He cited three specific claims:

  1. He was scheduled to speak at a pastors conference in November 2016, but alleged that missions board staff attempted, unsuccessfully, to get his appearance canceled.
  2. The missions board intentionally took steps to have his employment with the missions agency terminated—steps that proved successful.
  3. He was scheduled to speak in October 2016 at a missions symposium until missions board employees allegedly spoke to organizers of the event and had him uninvited.
The lawsuit

The plaintiff sued the missions board in a federal court, alleging three counts of intentional interference with business relationships. The court rejected the missions board’s motion to dismiss the case. It noted that under Mississippi law, the elements of intentional interference with a contractual relationship are:

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July 15, 2019



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