In
Azige v. Holy Trinity Ethiopian Orthodox Tewahdo Church, (NC App., Sept. 6, 2016), a North Carolina state appellate court dismissed on ecclesiastical abstention grounds a lawsuit by a faction of church members alleging that the church bylaws had been violated in extending the terms of certain parish council members and in taking other actions. The court said in part:
Although plaintiffs seek to present this dispute as a simple procedural disagreement over the adoption of bylaws in accord with proper procedure, the substance of the complaint belies this claim. The amended complaint alleges that each plaintiff is “a registered member” of the church; defendants dispute their membership....
Membership in a church is a core ecclesiastical matter. The power to control church membership is ultimately the power to control the church. It is an area where the courts of this State should not become involved....
The issues before us would require interpretation of the bylaws which do impose doctrinal requirements. Even if a declaration of plaintiffs’ status as registered members is not specifically the issue before us, in order to determine if plaintiffs even have standing to bring the other issues or to determine if the correct number of members voted for the challenged amendments, the trial court would need to address the contested membership status...
