In
Rosenberger v. Jamison, (FL App., Sept. 16, 2011), a Florida state appellate court held that deciding a dispute about governance of the First Baptist Church of Micanopy would unconstitutionally entangle the court in a religious controversy. The church's governing documents were changed to move it from a congregational-led church to one governed by elders. Four opponents of the change were terminated from membership. They sued to reverse their expulsion and revoke the change in the church's governing documents, claiming that these actions were taken without following the procedures set out in the then-existing Articles and Bylaws of the church. The court said:
[T]he issue before us is whether the First Amendment prohibits judicial review of actions taken by a corporation allegedly in violation of its articles of incorporation and bylaws when the corporation is a church....
[E]xercising jurisdiction in this instance would be tantamount to “intervening on behalf of [a group] espousing particular doctrinal beliefs.” We can discern no way under the facts of this case to draw a clean line between essentially religious matters protected by the First Amendment and matters of corporate law.
