In McRaney v. North American Mission Board of the Southern Baptist Convention, Inc., (5th Cir., Sept. 9, 2025), the U.S. 5th Circuit Court of Appeals, in a 2-1 decision, held that the church autonomy doctrine bars civil courts from adjudicating tortious interference, defamation and infliction of emotional distress claims by a Baptist minister who was fired from his position as Executive Director of the Baptist Convention of Maryland/ Delaware (BCMD). In that position he was to implement a strategic partnership between the North American Mission Board (NAMB) and BCMD. NAMB became dissatisfied with the way that plaintiff was carrying out the evangelical mission of the strategic partnership agreement, and plaintiff claims that NAMB was behind his firing by BCMD.
The court said in part:
... [T]he church autonomy doctrine prohibits far more than civil judges telling religious institutions what to believe or how to worship. To help clarify the wide-ranging scope of the doctrine, we identify some areas where church autonomy has barred judicial interference. These include (a) the selection and dismissal of clergy and faith leaders (the so-called “ministerial exception”); (b) the meaning of religious beliefs and doctrines; (c) the determination of religious polity, such as membership, matters of discipline and good standing, and the identification of the “true church” amidst internecine disputes; and (d) internal church communications regarding any of the aforementioned activities....
... [T]he church autonomy doctrine has numerous features of a jurisdictional bar. It limits the powers of federal courts. It immunizes ecclesiastical organizations from suit, not just liability. And, when it is denied, it gives rise to an immediate appeal. But ... the fact that some religious questions are beyond our judicial power does not mean that all church-autonomy disputes are properly dismissed under Rule 12(b)(1). Nor does it preclude federal courts from rendering judgment on the merits in cases like this one. ...
On the merits, the church autonomy doctrine bars all of McRaney’s claims against NAMB. Although his claims are facially secular, their resolution would require secular courts to opine on “matters of faith and doctrine” and intrude on NAMB’s “internal management decisions that are essential to [its] central mission.”...
At the outset, McRaney argues that the church autonomy doctrine cannot apply in this case because “NAMB is not a church,” “BCMD is not a church,” and “[t]here is no Baptist church; only Baptist churches.” ... He argues his case “does not involve an intra-church dispute in any respect, nor is it about church governance.”... Our dissenting colleague agrees..... On the dissent’s view, the church autonomy doctrine only protects religious entities “in which there are superior ecclesiastical tribunals”.... Having branded Baptists ecclesial anarchists, the dissent subjects the NAMB and BCMD’s actions to searching judicial scrutiny—as if this were just an ordinary employment dispute.
We respectfully disagree....
The church autonomy doctrine is triggered by the subject matter of the dispute, not the organizational structure of the disputants. The subject matter of this dispute is an evangelism project. Its stakes are eternal not judicial. And it matters not one bit that the particular evangelicals before us happen to be Baptists from different non-hierarchical congregations instead of soul-saving Presbyterians from a singular hierarchical one. ...
William McRaney sued a board of an organization for which he did not work, alleging interference with contract, interference with prospective business relations, defamation, and intentional infliction of emotional distress. Because his secular claims against a third-party organization do not implicate matters of church government or of faith and doctrine, I respectfully dissent....
Because they do not implicate matters of faith and doctrine, McRaney is entitled to continue pursuing his secular claims regarding NAMB’s pre- and post-termination conduct....
Baptist News Global reports on the decision.
