Fired Principal of Seventh Day Adventist School Can Pursue Her Claim

In Galetti v. Reeve, (NM App., May 28, 2014), the New Mexico Court of Appeals held that the church autonomy doctrine does not require dismissal at this time of a damage claim by a former principal and teacher at a Seventh Day Adventist school who was fired from her position. Plaintiff claims that she was harassed by by her supervisor and was fired in retaliation for filling a complaint about it. The court held that the trial court erred in dismissing her breach of contract, retaliatory discharge, intentional interference with contract, civil conspiracy, and defamation claims, saying:

The First Amendment does not immunize every legal claim against a religious institution or its members, but only those claims that are rooted in religious belief.

It added that if later it becomes apparent that any of the claims turn on matters of doctrine or church governance, summary judgment may be proper then.