In In re Fort Bend Christian Academy, (TX App., June 23, 2026), a Texas state appellate court held that the ecclesiastical abstention doctrine bars some of the claims brought by parents of a high school student who suffered traumatic brain injury during football practice at the Christian college preparatory high school. The court said in part:
... [T]he Hagans alleged that the Academy breached its obligation to make academic accommodations for B.H. after he suffered the brain injury. The Academy, however, is a college preparatory school committed to offering “a superior academic experience integrated with a consistent, Christian worldview and biblical perspective.” Accordingly, the Hagans’s claims alleging the Academy failed to accommodate B.H. do not turn on neutral principles of law but on the Academy’s application of its policy governing when — and to what extent — it modifies its biblically-based curriculum for students....
Additionally, the Hagans alleged that, before B.H.’s enrollment, Academy officials made specific promises that he would not be subjected to bullying and harassment....
We conclude these claims too concern ecclesiastical matters over which the trial court lacks jurisdiction because they arise from the Academy’s application of internal policies grounded in religious doctrine. These claims are premised on the Academy’s alleged failure to enforce its anti-bullying policy and prevent students from bullying B.H. But the policy states the Academy will provide “discipline that [is] Bibliocentric,” and that its approach to discipline is for students “to grow in self-discipline according to God’s Word so that external discipline measures become less needed.”... Consequently, the trial court cannot adjudicate these claims without deciding questions of religious doctrine and interfering with the Academy’s internal governance....
[The ecclesiastical abstention doctrine] does not bar the Hagans’s negligence claim, brought on B.H.’s behalf for personal-injury damages, because that claim arises from duties imposed by law — independent of any agreement between the Academy and the Hagans — and may be adjudicated under neutral tort principles without imposing liability on the Academy for complying with its religious-based policies....
Finally, we consider the doctrine’s application to the Hagans’s breach of contract, promissory estoppel, and DTPA claims to the extent those claims allege that the Academy breached concussion-management obligations arising from its TAPPS [Texas Association of Private and Parochial Schools] membership....
We conclude that the claims seeking to hold the Academy liable for breaching alleged concussion-management obligations arising from its TAPPS membership present secular, non-ecclesiastical issues over which the trial court may exercise jurisdiction....
