In
Mason v. Presbytery of San Francisco, (CA App., June 25, 2013), a California state appellate court dismissed under the "ecclesiastical deference" doctrine a lawsuit by a candidate for the Presbyterian ministry who sought access to her full candidacy file when, after ten years in the process, her candidacy was terminated. The court said that deciding whether there had been a contractual agreement to furnish the file to plaintiff at the end of her candidacy process, even if she did not receive a call to the ministry:
would require the courts to become embroiled in matters of church polity relating to the consideration of candidates for ministry and the handling of confidential or sensitive information received during the candidacy process. Thus, it is not possible for the courts to resolve the contract dispute alleged in the [complaint] without becoming entangled in matters of church polity.
The court also noted that in 2003:
the Permanent Judicial Commission of the General Assembly of the Presbyterian Church ,,, concluded, in a different matter, that respondent was not required to provide a candidate confidential documents relating to termination of the candidate.
