6th Circuit Dismisses Claims Growing Out of Church Discipline

In Ogle v. Church of God, (6th Cir., Oct 31, 2005), the U.S. Sixth Circuit court of Appeals held that the courts lack subject matter jurisdiction as a matter of First Amendment law over a suspended clergyman's claims of breach of implied contract, tortious interference with business relationships, invasion of privacy, conspiracy, intentional infliction of emotional distress, and defamation. The claims were filed after the Church of God delayed reinstating Troy Ogle as a pastor after his one year suspension by the church. An ecclesiastical panel had found Ogle guilty of conduct unbecoming a minister and ordered him to undergo counseling. The court held that the Free Exercise clause bars the court from adjudicating the numerous civil claims which Ogle had filed because they all grew out of church internal disciplinary proceedings. Those proceedings were initiated because Ogle's actions in making sexual advances to other men violated the Church of God Minutes of the General Assembly.