In Couzens v. City of Forest Park, Ohio, (6th Cir., Aug. 27, 2024), the U.S. 6th Circuit Court of Appeals affirmed the dismissal of a suit brought by a church's former pastor against off-duty city police officers who assisted the congregation in physically removing a pastor who had been dismissed from his position by the congregation. The court concluded that the off-duty officers acted reasonably in threatening to arrest the pastor if he did not leave the premises. It also concluded that the pastor's free exercise rights had not been infringed, saying in part:
Couzens contends that the Forest Park Defendants interfered with his free exercise of religion when the officers threatened to arrest him during a church service. He relies primarily on Kedroff v. St. Nicholas Cathedral of Russian Orthodox Church in N. Am., 344 U.S. 94 (1952)....
Kedroff’s church-autonomy doctrine, though, guarantees the independence of ecclesiastical bodies, not individuals.... And, unlike in Kedroff, the officers’ actions here did not reflect the state’s preference for one contender for a church’s control over another. Instead, the officers attempted to enforce what, from their perspective, appeared to be a settled matter: Couzens’s removal as IBC’s pastor....
