In Lovelace v. Mt. Zion Baptist Church, (MI App., July 15, 2026), a Michigan state appellate court, invoking the ecclesiastical abstention doctrine, affirmed a trial court's dismissal of contract and defamation claims by a pastor whose employment contract was cancelled by a vote of church members. The court said in part:
We first address plaintiff’s ... theory ... that the church breached the agreement by terminating him for actions he was contractually permitted to take. This theory would require a civil court to decide whether church leadership correctly concluded that plaintiff had “abused his authority”.... That inquiry would require the court to decide questions of church governance and authority. “Under the ecclesiastical abstention doctrine, apparently derived from both First Amendment religion clauses, civil courts may not redetermine the correctness of ... some decision relating to government of the religious polity.”...
Here, plaintiff asks us to determine that the church and its leadership exceeded their authority when they called the April 2022 meetings to discuss his future as senior pastor and invited guest pastors to oversee those meeting....
Under the ecclesiastical abstention doctrine, a civil court may not decide those questions because it would generally be inconsistent with religious liberty for civil courts to “inquire into the regularity of the proceedings of church tribunals having cognizance of such matters....
... [E]ven the seemingly straightforward question whether the termination process in plaintiff’s employment agreement was followed cannot be answered here through neutral legal principles without infringing on the religious liberty of the church and its members....
... [P]laintiff’s tortious-interference claim fails because he cannot establish that the individual defendants were third parties to the employment agreement. And even if plaintiff could satisfy that threshold requirement, adjudicating the breach and justification elements of his claim would require the resolution of ecclesiastical questions...
Plaintiff’s defamation theory is that the individual defendants stated that he lacked authority to access the church’s bank accounts, and that this statement was false because his employment agreement gave him broad authority over the church’s spiritual and secular affairs....
For the statement to be actionable, however, a civil court would have to determine that it was false.... The statement ... would be provable as false only if the trial court parsed the agreement and determined which powers belonged to the senior pastor.
