Neutral Principles Approach Allows Court To Hear Various Claims Against Methodist Annual Conference

In Beach v. Budd, (MN App., May 3, 2011), Samantha Beach, a  parishioner at a Minnesota Methodist church, sued Donald Budd, the church's pastor, and the Minnesota Annual Conference that controls the church and employed Budd. Plaintiff's claims grew out of sexual contact that Budd had with Beach at the same time he was counseling her. This opinion involved an interlocutory appeal by the Conference challenging the court's jurisdiction on 1st Amendment grounds, alleging that the court would become excessively entangled with religious matters. The court held first that:

The Establishment Clause’s prohibition against government entanglement with religion does not deprive the district court of subject-matter jurisdiction over Beach’s negligent-retention, negligent-supervision and sexual-exploitation claims because such claims can be resolved according to neutral principles of law.

The court, however, held that Beach's negligent investigation claim should be dismissed because the Conference "owed no duty to protect Beach or to investigate her complaint apart from its obligations as Budd's employer."