Ecclesiastical Abstention — UPDATED

The Fifth Court affirmed the dismissal, on ecclesiastical-abstention grounds, of a fraud claim about the handling of a sex-abuse claim by the Roman Catholic Diocese of Dallas: “The district court determined that (i) the Dallas Diocese’s Sexual Misconduct Policy (Policy) was ‘an outgrowth of, or so integrally related to, the Dallas Diocese’s dogma that it comprises part of the Dallas Diocese’s religious representations, beliefs, and teachings,’ (ii) Doe’s fraud claim required Doe to prove the Dallas Diocese’s material representations to Doe were false, and (iii) the First Amendment to the Constitution of the United States prohibited the trial court from adjudicating the truth or falsity of religious doctrines or beliefs. Because Doe’s claims require resolution of matters of church government, we affirm the judgment of the trial court.” Doe v. Roman Catholic Diocese of Dallas, No. 05-19-00997-CV (Aug. 11, 2021) (mem. op.).