Ecclesiastical Abstention Doctrine Requires Dismissal of Pastor's Contract Claim

In In re First Christian Methodist Evangelistic Church, (TX App., Aug. 30, 2019), a Texas state appellate court held that the ecclesiastical abstention doctrine, as a matter of constitutional law, prevented civil courts from adjudicating a pastor's claim that he was entitled to 6 months severance pay under his employment contract. The court said in part:

[T]o determine if the Church was required to pay the Senior Pastor severance under the contract, the trial court will be required to determine why the Senior Pastor was terminated and, if the termination was for misconduct, the court will be required to determine if the Senior Pastor was properly terminated for misconduct as defined by the Church’s Book of Discipline and ecclesiastical rules.... The ecclesiastical nature of the dispute cannot be severed from the contractual issues asserted by the Senior Pastor.