Teacher's Defamation Suit Dismissed Under Ecclesiastical Abstention Doctrine

In Becker v. Clardy, (TX App., Dec. 22, 2011), a Texas appellate court applied the ecclesiastical abstention doctrine to dismiss a defamation action brought by a religion teacher in a Catholic parochial school against a fellow religion teacher.  Teacher Kenneth Becker claimed that teacher Carla Clardy made negative comments about him in front of students in her eighth grade religion class. Clardy resigned while an investigation of the incident by the school's principal and pastor was pending. At that point the investigation stopped. According to the court, Becker claimed only damage to his reputation within the Church community, and the substance of his claim was that Clardy violated the Diocese of Austin Policies on Ethics and Integrity in Ministry. Finding that application of the ecclesiastical abstention doctrine is not limited to suits against authority figures, the court concluded:

Becker chose not to sue the school for its lack of action against Clardy, but brought his claims directly against Clardy. A civil court action resolving Becker’s claims then would encroach on the church’s "ability to manage its internal affairs."