Dispute Over Selection of New Pastor Dismissed Under Ecclesiastical Abstention Doctrine

In Mouton v. Christian Faith Missionary Baptist Church, (TX App., May 24, 2016), a Texas state appeals court dismissed on ecclesiastical abstention grounds a dispute between two groups in a church over who should be its new pastor.  The court said in part:

Appellants contend that their claims arise solely from the church’s failure to abide by non-ecclesiastical terms of the church’s bylaws and, therefore, the trial court had jurisdiction to adjudicate the case under neutral principles of law.  According to appellants, the questions they raise—including whether appellees complied with church bylaws in electing Wilson as pastor and whether appellees properly expelled appellants from church membership—are non-ecclesiastical because they are governed by non-ecclesiastical provisions in the church’s corporate documents. We conclude that the trial court correctly granted the plea to the jurisdiction because appellants’ claims are inextricably intertwined with inherently ecclesiastical issues