In Yakob v. Kidist Mariam Ethiopian Orthodox Tewahedo Church, Inc., (GA App., March 16, 2021), a Georgia state appeals court, in a dispute between the church's administrative board and its former priest Abba Yakov (who also served as Archbishop over several churches), reversed the trial court's grant of an interlocutory injunction to compel attendance of board members at board meetings. It held that the interlocutory injunction altered the status quo. However the court affirmed the trial court's interlocutory injunction that gave access to the two factions to conduct services at different times. The challenged portion of that injunction dealt with Yakob's role during the times that the opposing faction had access. It provided:
Defendant Yakob may attend the Church’s services as a parishioner, but he is prohibited from presiding over, controlling, or attempting to preside over or control the Church’s services in any way. Defendant Yakob may enjoy the Church’s services from the pew, but he may not enter areas of the Church’s sanctuary for which access to parishioners is prohibited and may not participate in those services in any role other than as a parishioner.
The court concluded:
[T]he complaint addresses itself to matters outside of First Amendment jurisprudence, such as issues of Church property and board governance issues. Given the Church’s hybrid form of governance ..., those property and governance issues are capable of resolution by reference to neutral principles of law. Importantly, nothing in the April 2017 injunction relates to the propriety or validity of Yakob’s termination as priest, or his role as Archbishop.
