Thou Shalt Not Sue
January 31, 2013The court affirmed the dismissal of an action for lack of subject matter jurisdiction based upon the ecclesiastical abstention doctrine. Jennison, a former Episcopal Priest, sued Prasifka, an Episcopal Church parishioner, for slander, tortious interference with a contractual relationship, and wrongful discharge, stemming from complaints she made to a church official in response to a request by the church in connection with internal church disciplinary proceedings against Jennison. The proceedings resulted in his discharge from the priesthood. Prasifka filed, and the court granted, a motion to dismiss because the action involved church matters outside of the court’s jurisdiction.
On appeal, the court noted that the ecclesiastical abstention doctrine removes most issues related to a church’s ministerial employment decisions from the jurisdiction of the civil courts. In this case, Prasifka’s defamatory statements were made entirely in connection with church disciplinary proceedings. These statements and Jennison’s claims were inextricably intertwined with the church’s investigation and thus closely related to internal matters of church governance and discipline. Further, a causation determination would require an analysis of the church’s disciplinary decision-making process. Thus, the ecclesiastical abstention doctrine applied and the district court lacked jurisdiction.
