In Taylor v. Evangelical Covenant Church, (IL App., Jan. 12, 2022), an Illinois state appeals court dismissed on ecclesiastical abstention grounds a suit by a pastor against his former church for breach of contract and intentional interference with economic advantage. Plaintiff claimed that the church carelessly handled an investigation into malicious accusations against him of sexual assault supposedly occurring some forty years earlier, before plaintiff became a pastor. Plaintiff was suspended during the investigation, and after the suspension was lifted he was never returned to his former position. The court said in part:
Even viewed in the light most favorable to him, plaintiff’s claims arise from a wholly internal investigation and suspension conducted by his church. Plaintiff’s claims are inexorably intertwined with defendant’s investigation as to whether he was fit to serve as a pastor, given the accusation of sexual misconduct against him. That is, the substance of plaintiff’s complaint relates to internal matters of church governance and discipline. Ecclesiastical abstention is required because this case necessarily involves matters of internal discipline.... [N]o matter how egregiously defendant may have departed from proper investigatory procedures, the subject matter of the dispute makes abstention compulsory.
