Freedom of religion; The ecclesiastical abstention doctrine; U.S. Const. amend. I; Const. 1963, art. 1, § 4; Winkler v. Marist Fathers of Detroit, Inc.; Pilgrim’s Rest Baptist Church v. Pearson; Van Vliet v. Vander Naald; First Protestant Reformed Church v. DeWolf; Dlaikan v. Roodbeen; Jones v. Wolf; Standing; MCR 2.116(C)(5); Kaiser v. Schreiber; Lansing Sch. Educ. Ass’n v. Lansing Bd. of Educ.; Detroit Fire Fighters Ass’n v. Detroit; Allstate Ins. Co. v. Hayes; Bowie v. Arder; Declaratory judgment; MCR 2.605(A)(1); Quo warranto; MCR 3.306(A) & (B); MCL 600.4501; Davis v. Chatman; City of Grand Rapids v. Harper; Evidence of negotiations & settlement; MRE 408; Gorman v. Soble

The court held that the trial court did not err by granting summary disposition for defendants-religious organization (IHOD) and trustees based on the ecclesiastical abstention doctrine and plaintiff-former trustee’s lack of standing. Plaintiff brought several claims against defendants, and sought a declaratory judgment that they “improperly diverted IHOD from its stated mission” and that he was “qualified to have possession and control of IHOD’s assets, or alternatively that” the Attorney General, acting through him, seek “dissolution of IHOD and escheat of its assets to the state.” The trial court ruled in favor of defendants, finding the ecclesiastical abstention doctrine supported dismissal, and that he lacked standing. On appeal, the court rejected plaintiff’s argument that the trial court erred by holding that his claims were barred by the ecclesiastical abstention doctrine. “The trial court did not err by ruling that resolution of plaintiff’s claims would require a decision on matters of church doctrine and polity.” And the damages he alleged were “spiritual in nature.” The matters at issue involved “ecclesiastical questions related to church doctrine and polity, disputes the trial court correctly abstained from deciding.” The court also rejected his claim that the trial court erred by ruling that he lacked standing based on his release of his membership and any rights attendant to that membership in a Settlement Agreement, as well as his agreement to have no contact with IHOD or its members for the rest of his life. It found that he was not an “interested party” as to IHOD, and that he “voluntarily relinquished any rights of membership and any rights attendant thereto in exchange for a settlement payment,” did not “participate in any of the activities or government of the group, and he agreed not to have contact with IHOD or any of its members for the remainder of his life.” His other claims were also properly dismissed because, “as a nonmember without any attendant rights in IHOD, [he] lacked standing to bring claims for any alleged injury resulting from the management or transfer of IHOD’s assets, or to bring any claims on behalf of IHOD itself.” Finally, the court rejected his contentions that the trial court erred by finding that the facts did not support his quo warranto claim, and by considering inadmissible evidence. Affirmed.