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 employee’s 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:

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Posted: July 15, 2019



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