In Payne-Elliott v. Roman Catholic Archdiocese of Indianapolis, Inc., (IN Ct. App., Nov. 23, 2021), an Indiana state appellate court reversed a trial court's dismissal of a suit by a former teacher in a Catholic high school who claimed that the Archdiocese intentionally interfered with his contractual and employment relationships with the school. After plaintiff married his same-sex partner, the Archbishop insisted that the school terminate his teaching contract or else it could no longer designate itself as "Catholic." In rejecting dismissal of the suit, the appeals court said in part:
Here, the parties have yet to undertake the requisite “fact-sensitive and claim specific” analysis that must precede analysis of whether the First Amendment bars Payne-Elliott’s claims against the Archdiocese. For instance, do genuine issues of material fact exist regarding: (1) whether Payne-Elliott’s job duties as a teacher at an Archdiocese-affiliated school rendered him a “minister”; or (2) the applicability of the ecclesiastical abstention doctrine? At this juncture, discovery in this matter is ongoing, and we find that this matter is well shy of being ripe for summary disposition....
Moreover, at this very early juncture, this Court cannot say that “it appears to a certainty on the face of the complaint” that Payne-Elliott is not entitled to any relief.... Nor can we say that the allegations present no possible set of facts upon which the complainant can recover.
WISH-TV News reports on the decision.
