Ex-Employee’s Lawsuit Against Church Fails Under Church Autonomy Doctrine

A Florida state appeals court ruled that it was barred by the “ecclesiastical abstention doctrine” from resolving a dismissed church employee’s lawsuit against her former church.

Background

A woman (the “plaintiff”) was hired as an office manager by a Catholic church.

Twelve years later, the church’s pastor and the plaintiff executed an employment agreement for the first time. The agreement, which purported to bind the church and local diocese, provided that the plaintiff would remain employed for four years, allowed termination only for cause, and required six months advance notice to avoid an automatic renewal.

Soon thereafter the local bishop appointed a new pastor for the church who promptly terminated the plaintiff’s employment without notice in violation of the employment agreement, allegedly due to a reduction in workforce.