Friday, April 19, 2013

Pastor's Suit For Defamation Dismissed Under Ecclesiastical Abstention Doctrine

In Torralva v. Peloquin, (TX App, April 18, 2013), a Texas appeals court held that the ecclesiastical abstention doctrine and the ministerial exception bar defamation, interference with contract and infliction of emotional distress claims brought by a Baptist associate pastor against his church's former head pastor, a deacon and three other congregants.  Plaintiff Armando Torralva alleged that defendants attempted to destroy his character and ruin him socially by claiming that a picture he e-mailed to the church's head pastor amounted to pornography.  The picture, from publicity by another church for a program for married couples, showed a fully clothed couple lying in bed embracing, and was captioned "Ignite Your Marriage ... Mattress Not Included."

In dismissing Torralva's claims, the appeals court said:
Each of Torralva’s causes of action are based on appellees’ allegedly taking action against him for conduct that they viewed as inappropriate for an associate pastor. There was no evidence adduced that Torralva’s reputation was harmed outside of the Church community.... Thus, trial on Torralva’s claims would require an analysis of "church discipline, ecclesiastical government, or the conformity of the members of the church to the standard of morals required." ... The ecclesiastical abstention doctrine precludes subject matter jurisdiction over those causes of action.

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