Court Dismisses Priest's Suit Against Parishioner On Ecclesiastical Abstention Grounds

In Jennison v. Prasifka, (TX App., Jan. 28, 2013), a Texas state appellate court invoked the ecclesiastical abstention doctrine to dismiss a suit by an Episcopal priest against a parishioner alleging slander, tortious interference with contractual relationship and wrongful discharge. Plaintiff, Raymond Jennison, who also was a stockbroker, sued over a letter that Jeanette Prafiska had written to the Bishop complaining that Jennison had been churning her brokerage account.  In response the Bishop placed Jennison on inactive status as a priest. The court held:

Jennison’s claims ... are inextricably intertwined with the church’s investigation of his performance as a priest and the discipline imposed by the church for inadequate performance.... Therefore, adjudication of Jennison's claims would neccessariIy require an inquiry into and interpretation of canon law, application of church policies, and the church’s assessment of Jennison’s fitness to perform the duties of a priest....[This] would impinge upon the church’s ability to manage its internal affairs and impair the effectiveness of the church’s disciplinary process.