In Family Federation for World Peace and Unification International v. Hyun Jin Moon, (DC Ct. App., July 3, 2025), the District of Columbia Court of Appeals affirmed the trial court's final dismissal of a lawsuit surrounding a schism and succession dispute in the Unification Church. The dispute has been in litigation for 14 years and has been before the Court of Appeals three times previously. (See prior posting.) Among the numerous issues dealt with in the Court's 59-page opinion was whether the ecclesiastical abstention doctrine applies to the dispute. The Court said in part:
... [A]ppellants argue that the trial court erred by (1) finding that resolution of the contract claims required determining questions of disputed religious doctrine; and (2) after making that finding, failing to apply the fraud or collusion exception to nonetheless permit review of the contract claims....
At bottom, appellants have yet to provide a clear, spelled-out answer as to how a court or jury might parse their contract and quasi-contract claims through neutral principles of law. Pointing us to any and all potential contract conditions in the record does not cure the underlying problem we identified in Moon III—which was reiterated by the trial court on remand—that any path of decision-making analysis would require deciding actual, disputed questions of religious doctrine or leadership. This necessarily results from the combination of (1) the use of extraordinarily broad, religious language in the purported contract terms and (2) an intrachurch dispute about the meaning of that language. The contract-related claims therefore must fail under the baseline religious abstention doctrine....
Preston has only fraudulently donated UCI’s assets if he is not the true leader of the Unification Church and he knows it. We cannot say the first thing without running afoul of the abstention doctrine, as we made clear in Moon III, and if bare allegations of fraud or collusion could get us around that, then the courts would be thrust right back into resolving core theological disputes about religious doctrine, hierarchy, and succession. “No thanks” to that—that runs afoul of the abstention doctrine’s central animating principles. And it is well established that we cannot apply any fraud or collusion exception in a way that violates the existing Supreme Court precedent on religious abstention....
The trial court acted well within its discretion to put an end to this decade-old case rather than breathing new life into it on its deathbed years after appellants could have gone after the discovery they now belatedly seek.
