In St. John Missionary Baptist Church v. Flakes, (TX App., Nov. 30, 2020), a Texas state appeals court affirmed the dismissal, on ecclesiastical abstention grounds, of a suit between two factions of a church. One faction attempted to remove the pastor through a church meeting. The pastor refused to step down and the other faction continued to pay him. In dismissing the suit, the court said in part:
Texas courts have consistently held that the relationship between an organized church and its ministers is its lifeblood, and matters concerning this relationship must be recognized as of prime ecclesiastical concern.
The court similarly held that the questions of whether members excommunicated by one faction could enter the church and whether they could vote on sale of church property were also covered by the ecclesiastical abstention doctrine.
