In
Puri v. Khalsa, (9th Cir., Jan. 6, 2017), the U.S. 9th Circuit Court of Appeals, vacating the district court's dismissal, held that neither the ministerial exception doctrine nor the ecclesiastical abstention doctrine requires dismissal of a suit by the widow and children of the deceased spiritual leader of the Sikh Dharma faith alleging they are being frozen out of board positions in two nonprofit Sikh Dharma entities. In rejecting application of the ministerial exception doctrine, the court said in part:
[T]he pleadings do not allege the board members have any ecclesiastical duties or privileges. In assessing the responsibilities attendant to the board positions, it is relevant that the entities involved are not themselves churches, but rather corporate parents of a church. SSSC’s primary responsibility appears to be holding title to church property, and UI, in addition to being ... the direct corporate parent of the Sikh Dharma church – owns and controls a portfolio of for-profit and nonprofit corporations, including a major security contractor and a prominent tea manufacturer. Although the complaint alleges the board members have “fiduciary duties to UI and SSSC to hold assets in trust for the benefit of the Sikh Dharma community,” it is not clear on the face of the complaint that these duties are “religious” or “reflect[] a role in conveying the Church’s message and carrying out its mission.”
Turning to the ecclesiastical abstention doctrine, the court said:
Nothing in the character of th[e] defense will require a jury to evaluate religious doctrine or the ‘reasonableness’ of the religious practices followed . . . Under these circumstances, the availability of the neutral-principles approach obviates the need for ecclesiastical abstention.
