Freedom of religion; Pilgrim’s Rest Baptist Church v Pearson; The ecclesiastical abstention doctrine; Winkler by Winkler v Marist Fathers of Detroit, Inc; First Protestant Reformed Church v DeWolf; “Religious doctrine”; Maciejewski v Breitenbeck; Intentional infliction of emotional distress (IIED); Lucas v Awaad; Misrepresentation & invasion of privacy; Swickard v Wayne Cnty Med Exam’r; Vicarious liability & negligent hiring, supervision, or retention; Principal liability for an agent’s acts; Rogers v JB Hunt Transp, Inc

The court held that because defendant-Catholic priest’s (Father LaCuesta) conduct was protected by the ecclesiastical abstention doctrine, it may not pass judgment on the content of his sermon. Thus, it affirmed the trial court’s grant of summary disposition for defendants-Archdiocese, church, and Father LaCuesta. Plaintiff sued defendants after Father LaCuesta revealed her son’s suicide during his funeral and preached about suicide as a grave sin that endangered her son’s immortal soul. The trial court found Father LaCuesta’s conduct was protected by the ecclesiastical abstention doctrine, and plaintiff’s negligent hiring, supervision and retention allegation was barred for other reasons. The court found that the trial court “did not err by concluding that resolution of plaintiff’s claims would require a decision regarding matters of church doctrine and polity” and thus, the doctrine barred plaintiff’s claims. Plaintiff contended that her claims concerned “an agreement by Father LaCuesta to preside over the funeral service for her son—for which Father LaCuesta was compensated through a donation—in accordance with requests from [plaintiff’s] family regarding the content of the funeral service. But the actual adjudication of each of plaintiff’s claims would require an inquiry into religious doctrine and practices regarding sermons and funeral services, suicide, as well as why Father LaCuesta chose the words that he did, and personnel issues regarding hiring practices of the Catholic Church.” The court found that the trial court “properly applied the ecclesiastical abstention doctrine to bar plaintiff’s” IIED claim, noting that to find the content of Father LaCuesta’s homily at the funeral “extreme” or “outrageous” would require the trial court “to evaluate Catholic philosophy and doctrine regarding suicide, and whether Father LaCuesta complied with it.” Under Winkler, this “inquiry would be inappropriate.” The trial court also did not err when it ruled the “doctrine barred plaintiff’s claims of misrepresentation and invasion of privacy.” It correctly determined “that resolution of these claims would require evaluating religious doctrines and, by extension, trigger the” doctrine. The trial court was also “correct in concluding that plaintiff had no cognizable privacy interest in the fact that her son committed suicide.” Finally, the trial court properly “concluded that the ecclesiastical abstention doctrine barred plaintiff’s claims for vicarious liability and negligent hiring, supervision, or retention.” It agreed with defendants that the “Roman Catholic Church is an hierarchical organization and the Bishop’s power to make assignments of ministers to a parish is certainly a matter of ecclesiastical polity in which the courts may not interfere.”