In San Jose Korean Central Church v. Korean Evangelical Church of America, (CA App., May 29, 2024), a California state appellate court applied the ecclesiastical abstention doctrine, holding that a trial court was required to accept as binding internal disciplinary judgments by a church's parent body, Korean Evangelical Church of America (KECA). At issue was an attempt by a local congregation, San Jose Korean Central Church (SJKCC) to disaffiliate from KECA. As explained by the court:
... [T]he board of SJKCC, led by its senior pastor, Francis Chung, purportedly approved new bylaws and voted to disaffiliate itself from KECA. One week later, at a special meeting set by the board, the congregation ... approved the new bylaws and voted in favor of SJKCC’s disaffiliation from KECA. Prior to these actions, however, KECA had issued a disciplinary judgment suspending Chung from performing his duties as an SJKCC board member. KECA therefore contended that the purported actions taken by the SJKCC board, with Chung acting as its chairman ... were void. As a result of Chung’s disobedience of the judgment of suspension, ... KECA entered a further disciplinary judgment revoking Chung’s SJKCCs pastorship and excommunicating him from KECA. Shortly before that date, ... KECA entered a disciplinary judgment against two Chung allies, Ki Soo Kim, Jung Young Lee, removing their status as elders and as members of the SJKCC board....
... [I]t is plain that the May 26, 2019 judgment suspending Francis Chung—being a disciplinary action taken by the national hierarchical church, KECA, through the Judgment Committee of its Northern California District Conference—was an internal ecclesiastical decision that was not subject to review by the civil judicial system. The rule of judicial deference to ecclesiastical matters applies not only to decisions related to matters of religious doctrine; it “also [applies to] issues of membership, clergy credentials and discipline, and church polity and administration.... The rule of deference to internal decisions of clergy discipline applies irrespective of whether the action taken was “by a procedure contrary to church law and regulations, and for improper, false and fraudulent motives.” ...
