Texas Court Bars Employment Claims Due to Ecclesiastical Abstention Doctrine
The ecclesiastical abstention doctrine can provide religious institutions with protection from employment-related lawsuits. Based upon the religious freedom amendments contained in the U.S. and Texas constitutions, this doctrine generally bars courts from adjudicating disputes related to the governance and operations of religious institutions. As seen in a recent decision by the Court of Appeals for the Fifth District of Texas, the ecclesiastical abstention doctrine can provide protection to seemingly ordinary employment decisions by religious entities.
In Kelly v. St. Luke Community United Methodist Church, the court considered a dispute between a church and Evelyn Kelly, a former employee. The church had employed Kelly as director of operations for 12 years prior to her discharge. While she was on medical leave, the church held an emergency meeting to discuss her employment and discharge. During that meeting, it was communicated to committee members and laypersons that a police officer was needed to escort Kelly off the premises during the termination process because she was volatile. After she returned from medical leave, the church terminated her employment and a police officer escorted her off the church premises. The church stated that it discharged her because the church was undergoing a reorganization of its programming and staff to conform its outreach to the Methodist church’s tenets and eliminated her position as a result of such efforts.
Kelly filed a lawsuit alleging defamation, negligence, fraud and misrepresentation, and age and sex discrimination. The church sought dismissal of the claims through a plea to the jurisdiction and a motion for summary judgment, claiming that its actions were not subject to judicial review pursuant to the ecclesiastical abstention doctrine. The trial court granted summary judgment to the church on all of Kelly’s claims but did not dismiss those claims pursuant to the ecclesiastical abstention doctrine. Both parties appealed.
The Court’s Analysis
On appeal, Kelly urged that the ecclesiastical abstention doctrine did not apply because her claims did not involve matters of church administration, church governance, or theology. The church also appealed the trial court’s decision, arguing that the ecclesiastical abstention doctrine required the dismissal of the former employee’s claims.
The court observed that the ecclesiastical abstention doctrine extends beyond employment decisions related to ministerial positions. Instead, the ecclesiastical abstention doctrine provides that courts will abstain from reviewing decisions by religious institutions “pertaining to the internal governance of the church and involving only church leadership, members, and staff.” The court reviewed Kelly’s claims and determined that the substance of her claims related to matters of internal church governance (reorganization to conform with denominational tenets) and that all of her claims, other than defamation claims based on comments made outside of the church, were inextricably intertwined with these internal church governance matters. The court determined it would be inappropriate to impose civil liability on the church under these circumstances because it would impinge upon the church’s ability to manage its internal affairs.
This decision highlights the breadth of the ecclesiastical abstention doctrine as applied to employment decisions made by religious institutions. As noted by the court, the ecclesiastical abstention doctrine is much broader than the ministerial exemption, which prohibits court review of decisions made regarding church employees with ministerial functions. Under the court’s opinion, the ecclesiastical abstention doctrine bars court consideration of even routine employment law claims of sex and age discrimination, as long as the genesis of those claims is intertwined with matters of internal church governance.