In Bogle v. Sewell, (MI App., May 26, 2022), a Michigan state appellate court held that the ecclesiastical abstention doctrine did not preclude the trial court from deciding whether 2011 and 2019 amendments to the bylaws of Evangel Echos Church of the Air validly changed the church from a membership-based to a directorship-based governance. The court said in part:
Whether the Church was organized on a membership basis or a directorship basis was not an ecclesiastical question—it was a corporate law question. To answer this question, the trial court needed to look no further than the Church’s Articles of Association and the MNCA. Resolving the parties’ dispute did not require the trial court to interpret any of the Church’s religious doctrine or to pass judgment on what it believed to be the form of corporate governance most in line with the Church’s discipline or values. It simply required the trial court to apply Michigan statutory law against the language of the Articles of Association
