In Boyett v. First Baptist Church of Bossier, (LA App., Aug. 9,2023), a Louisiana state appellate court in a 2-1 decision affirmed the trial court's holding that Louisiana's statute of limitations (called "prescription" in Louisiana law) barred a suit by members who had been expelled from the church. Plaintiffs claimed that the Articles under which they were expelled had been improperly adopted. Judge Hunter dissenting argued that the majority applied the wrong statute of limitations, so that the trial court should reach the merits of the case using the "neutral principles of law" approach. He contended that the ecclesiastical abstention doctrine did not require dismissal of the case, and that the court should reverse the trial court's dismissal and remand the case for the taking of additional evidence.
