In Buck v. Peace Apostolic Church, Inc., (CA Super. Ct., March 8, 2024), a California trial court rejected the contention that the church autonomy or ecclesiastical abstention doctrine precludes the court from adjudicating a claim that two church officers and directors improperly spent church funds. The court said in part:
The First Amendment does not immunize the Church or the individual defendants from illegal acts that apply equally to everyone, religious or not. The Plaintiffs alleged and proved that Defendants committed fraud and engaged in false advertising. Defendants solicited donations from the public promising that “no part of the income or assets of this corporation shall ever inure to the benefit of any director, officer, or member thereof or to the benefit of any private person.”... Prince used her position in the church and the representations made by her and by the church to enrich herself. While Brown did not enrich herself, she facilitated the enrichment of her son, Howard Woods. The defendants cannot take money based on a representation that it would be used for charitable purposes and church mission and use it for personal benefit. That's not internal church governance. That's fraud. The activities that occurred in that case are not protected by the First Amendment....
On December 19, 2023, the Court ordered injunctive relief. In part, PAC was ordered to post warnings that read “WARNING: A Jury has found that Tamara Swancy-Prince, Priscilla Woods Brown and Peace Apostolic Church have improperly misappropriated donations.” PAC objects to the injunction arguing that the Court misapplied the law.... The Court is simply not convinced that similar abuses won’t recur.
