Imam's Contract and Defamation Claims Dismissed on Ecclesiastical Abstention Grounds

In Ahmed v. American Muslim Diversity Association, (MI App., Sept. 11, 2026), a Michigan state appellate court upheld the dismissal on ecclesiastical abstention grounds of defamation, breach of contract and related claims filed by an assistant Imam against his mosque and its board of trustees. The court said in part:

According to Ahmed, beginning in 2021 the individual defendants engaged in a “smear campaign” against him by falsely accusing him of lying while performing his duties as a religious leader and refusing to lead certain prayers.  He also alleged that defendants disparaged his character by discussing his recent divorce and the allegations of domestic violence that had been made against him....

The trial court correctly determined that resolution of Ahmed’s breach-of-contract claim would require the court to delve into ecclesiastical matters.  The contract stated that the board of trustees reserved the right to cancel the contract “if there are any violation [sic] in contractual agreement, any activities against principles of Islam, or any activity subversive to the mission and objective of AMDA by the Qa’ari Imam as determined by the Board of Trustees.”  Although the board of trustees determined the domestic-violence allegations could not be substantiated, it may have also determined that Ahmed violated the contract or engaged in activity contrary to the principles of Islam or subversive to AMDA’s mission and objective.  The ecclesiastical abstention doctrine precluded the trial court from examining and second-guessing the decision of the board of trustees that it would be best for AMDA if Ahmed no longer served as an assistant Imam....

... Ahmed alleged that defendants falsely stated he was not so qualified and lacked the character required and expected of an assistant Imam.  ... [T]his Court will not second-guess a religious entity’s investigation and evaluation of allegations involving its leaders or its method of communicating matters relevant to such allegations.  Because Ahmed’s intentional infliction of emotional distress and concert of action claims also involve evaluating defendants’ decisions and method of reaching their decisions, those claims fail for the same reasons.  Accordingly, the trial court did not err by granting defendants’ motion for summary disposition with respect to Ahmed’s tort claims.

Pastor's Suit for Breach of Contract and Defamation Is Dismissed Under Ecclesiastical Abstention Doctrine

 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.