In Nieto v. Great Bridge Presbyterian Church, Inc., (VA App., March 31, 2026), a Virginia state appellate court held that the ecclesiastical abstention doctrine required dismissal of a defamation suit brought by two pastors against the church that they formerly led. The complaint also alleged tortious interference with plaintiffs' pastoral relationship with the congregation. The claims grew out of a letter that was emailed to 750 persons after plaintiffs were dismissed from their pastoral relationship with their congregation.
The court said in part:
Here, the appellants base their defamation claims on a list of statements that can be categorized as either 1) purported mismanagement of funds or 2) the intimidation and shunning of “dissenters” or other members of the congregation. All statements in each category are barred from civil-court review because of the ecclesiastical-abstention doctrine....
Each of these statements would require us to evaluate and determine the appropriate financial management standard for pastors serving as leaders in the Presbyterian denomination and whether and to what extent the appellants may have breached that standard as determined by the denomination.... Great Bridge is a religious institution established as a local church by the Presbyterian denomination and therefore is subject to the religious denomination’s doctrinal and organizational documents, including certain policies and beliefs that pertain to proper church order, practices, governance, and leadership. ...
Without first determining the proper method that a pastor serving a Presbyterian church should responsibly exercise when administering the finances of a Presbyterian church, we cannot determine whether the statements regarding how the appellants allegedly misused that authority are actionable. And a secular judicial body determining the fitness and qualifications of the office of a pastor who governs a church would violate that church’s “autonomy with respect to internal management decisions that are essential to the institution’s central mission.”...
Similarly, we cannot use neutral principles of law to discern whether the statements about the intimidation and shunning of “dissenters” or other members of the congregation are actionable....
