5th Circuit Says Fired Employee's Suit Does Not Necessarily Require Deciding Ecclesiastical Questions

In McRaney v. North American Mission Board of the Southern Baptist Convention, Inc., (5th Cir., July 16, 2020), the U.S. 5th Circuit Court of Appeals reversed the dismissal of a suit by the former executive director of the General Mission Board of the Baptist Convention for Maryland/Delaware ("BCMD").  He alleged that the North American Mission Board ("NAMB") intentionally made false statements about him that led to his termination. He also claimed that NAMB posted his picture at their headquarters to tell people that he was not to be trusted.  The district court relied on the ecclesiastical abstention doctrine to dismiss the case.  The 5th Circuit, reversing, said in part:

In order to resolve McRaney’s claims, the court will need to determine (1) whether NAMB intentionally and maliciously damaged McRaney’s business relationships by falsely claiming that he refused to meet with Ezell,... (2) whether NAMB’s statements about McRaney were false, defamatory, and at least negligently made ...; and (3) whether NAMB intentionally caused McRaney to suffer foreseeable and severe emotional distress by displaying his picture at its headquarters.... At this early stage of the litigation, it is not clear that any of these determinations will require the court to address purely ecclesiastical questions.