In In re Gateway Church, (TX App., Aug. 19, 2026), a Texas state appellate court held that a state trial court should have dismissed on ecclesiastical abstention grounds. a defamation suit that was brought against a church and church leadership. At issue are statements that church leaders made about its investigation into charges that its then-pastor sexually abused a 12-year-old girl 30 years previously while he was pastor at another church. According to the court:
Gateway’s leadership issued a communication to church staff addressing the allegations and providing information about Morris’ past misconduct and the church’s understanding of events. The statement ... was intended to “empower” staff concerning a response should they receive any inquiries....
Although the communication was directed to staff, portions of it were later circulated on social media and reported in the news media. The mandamus record does not establish how the communication became public....
.... The [ecclesiastical abstention] doctrine prohibits civil courts from delving into ecclesiastical matters or a plaintiff’s claims that are inextricably intertwined with matters of doctrine or church governance.... Because we find that real parties’ claims are inextricably intertwined with the church’s investigation of Morris’ misconduct, the doctrine deprives the trial court of jurisdiction....
Gateway’s investigation into Morris (or, for that matter, lack of investigation if none was done prior to the communication) is inherently ecclesiastical. Gateway, through its leadership, was communicating with staff about what the church and elders knew about their senior executive pastor and events that transpired some three decades ago. As relators note in their petition, the challenged statements were made for a religious purpose, “shepherding the Gateway congregation in accordance with the dictates of Scripture.”...
... Claims related to a church’s publication or communication of the results of its own investigation cannot be severed from the church’s policy to investigate its clergy....
... Although real parties argue that establishing knowledge can be a secular fact question in a defamation case, determining what Gateway and its leaders knew, and how they arrived at that understanding, would necessarily involve probing internal church deliberations and processes. That inquiry is inextricably intertwined with ecclesiastical matters and is therefore prohibited....
KERA News reports on the decision.
