Church Autonomy Doctrine Leads Florida Court To Dismiss Workers' Comp Claim

A Florida state court of appeal yesterday held that under the church autonomy doctrine, civil courts may not review a Catholic Archdiocese's assertion that a workers' compensation claimant is an incardinated cleric and not an employee. In Malichi v. Archdiocese of Miami & Unisource Inc., (FL Ct. App., Nov. 8, 2006), the court held that determination of a priest's duties is a matter of the church's internal administration and government. The court said that it was not determining whether the First Amendment similarly precludes it from deciding a workers' compensation claim filed by a minister of a "congregational" or "presbyterial" church that does not have the same hierarchical structure and well-established body of canonical law as the Archdiocese.