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Religious Immunity Provision of First Amendment Did Not Apply to Contract Claim Made Against Church
Second Episcopal District African Methodist Episcopal Church v. Reverend Deloris Prioleau
In this case, Reverend Deloris Prioleau (“Prioleau”) filed a complaint against the Second Episcopal District African Methodist Episcopal Church and Cornerstone African Methodist Episcopal Church (collectively, “the Church”) alleging breach of contract. The Church filed a motion to dismiss for lack of subject matter jurisdiction, claiming immunity under the First Amendment. The D.C. Court of Appeals denied the Church’s Motion to Dismiss for lack of subject matter jurisdiction, finding that the contract claim could be sufficiently tried without entangling the religious doctrine.
On September 10, 2009, Prioleau filed a complaint alleging that the Church had failed to pay her $39,000 it owed her under the contract covering her final year as pastor. In April 2004, Prioleau was given charge to serve as pastor of the Cornerstone African Methodist Episcopal Church (“Cornerstone”) for one (1) year. Her contract was renewed for an additional three (3) years, with her last renewal in April 2007. When Prioleau first became pastor of Cornerstone, the Church was in dire financial straits. The church paid Prioleau in accordance with her contract during her first three (3) years there, but due to the financial difficulties faced by the Church, Prioleau agreed to receive her salary under a payment plan. In 2008, Prioleau was transferred to another church, but refused the transfer. She did not receive any payments from the Church going forward. Cornerstone’s Steward and Finance Board (“Board”) met in April 2008 to address, inter alia, the Church’s statement of accounts listing the individuals to whom money was owed. At this meeting, the Board recognized that they owed Prioleau $39,200.
The civil courts’ role in resolving disputes involving religious organizations has been severely limited by the Establishment Clause and the Free Exercise Clause of the First Amendment. Courts must be careful not to get involved in matters of religious doctrine, discipline, faith, ecclesiastical rule, custom or law. Churches may, however, be held liable under valid contracts not entangling religious doctrine. To determine whether civil courts have jurisdiction, courts must determine if they may employ “neutral principles of law.”
Additionally, civil courts are precluded from interfering with a religious organization’s right to choose its ministers. It is a church’s decision who to hire or fire and to prescribe the duties of the minister. This “ministerial exception” does not, however, bar all claims by ministerial employees.
The Court concluded that Prioleau was not precluded from pursuing her contract claim against the Church. The Court differentiated this case from the holding in Baltimore Annual Conference v. White, where the religious organization was granted immunity. In White, the employee brought wrongful termination claims in addition to contract claims. White, 571 A.2d at 793. Prioleau only requested payment pursuant to her contract and has not requested reinstatement; therefore, there is no risk of interfering with the Church’s right to choose its minister. Furthermore, the record demonstrates that the trial court should be able to resolve the claim using neutral principles of contract law.
For the reasons discussed above, the D.C. Court of Appeals, denied the Church’s Motion to Dismiss based on subject matter jurisdiction. The Court found that a trial court could properly resolve the contract claim without becoming entangled in the religious doctrine.
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