In Ahmed v. American Muslim Diversity Association, (MI App., Sept. 11, 2026), a Michigan state appellate court upheld the dismissal on ecclesiastical abstention grounds of defamation, breach of contract and related claims filed by an assistant Imam against his mosque and its board of trustees. The court said in part:
According to Ahmed, beginning in 2021 the individual defendants engaged in a “smear campaign” against him by falsely accusing him of lying while performing his duties as a religious leader and refusing to lead certain prayers. He also alleged that defendants disparaged his character by discussing his recent divorce and the allegations of domestic violence that had been made against him....
The trial court correctly determined that resolution of Ahmed’s breach-of-contract claim would require the court to delve into ecclesiastical matters. The contract stated that the board of trustees reserved the right to cancel the contract “if there are any violation [sic] in contractual agreement, any activities against principles of Islam, or any activity subversive to the mission and objective of AMDA by the Qa’ari Imam as determined by the Board of Trustees.” Although the board of trustees determined the domestic-violence allegations could not be substantiated, it may have also determined that Ahmed violated the contract or engaged in activity contrary to the principles of Islam or subversive to AMDA’s mission and objective. The ecclesiastical abstention doctrine precluded the trial court from examining and second-guessing the decision of the board of trustees that it would be best for AMDA if Ahmed no longer served as an assistant Imam....
... Ahmed alleged that defendants falsely stated he was not so qualified and lacked the character required and expected of an assistant Imam. ... [T]his Court will not second-guess a religious entity’s investigation and evaluation of allegations involving its leaders or its method of communicating matters relevant to such allegations. Because Ahmed’s intentional infliction of emotional distress and concert of action claims also involve evaluating defendants’ decisions and method of reaching their decisions, those claims fail for the same reasons. Accordingly, the trial court did not err by granting defendants’ motion for summary disposition with respect to Ahmed’s tort claims.
