Court Refuses To Apply Ecclesiastical Abstention Doctrine

In Jackson v. Mount Pisgah Missionary Baptist Church Deacon Board, (IL App., June 30, 2016), an Illinois state appeals court refused to apply the ecclesiastical abstention doctrine in a breach of contract suit by a pastor who employment was terminated by his church.  The pastor contended that the church had agreed that his employment would be governed by the church's bylaws.  The court held:

[P]laintiff alleges that defendants failed to (1) provide a written notice of dissatisfaction; (2) hold a special meeting; (3) provide notice of a vote to the members; and (4) have a proper membership vote. To resolve this dispute, we need only look to the plain text of the church’s bylaws and the relevant facts to determine whether or not defendants breached their oral agreement by failing to comply with its bylaws. Since we need not inquire into any religious doctrines, and can address this issue employing neutral principles of civil law, we have jurisdiction to decide whether defendants breached their oral agreement with plaintiff.

The court went on to agree with the trial court's finding that defendants were completely compliant with the bylaws in dismissing the pastor.