Breach of a pastor’s employment contract; Vincent v Raglin; Application of the ecclesiastical abstention doctrine; Winkler by Winkler v Marist Fathers of Detroit, Inc; Smith v Calvary Christian Church; The “ministerial exception” to employment-discrimination law; Weishuhn v Catholic Diocese of Lansing; Intentional interference with contractual relations; International Outdoor, Inc v SS Mitx, LLC; Corporate agents’ liability; Reed v Michigan Metro Girl Scout Council; Defamation; Ghanam v Does

The court held that plaintiff-former pastor’s breach of employment contract claim was properly dismissed under the ecclesiastical abstention doctrine. Further, his tortious-interference claim failed because he could not “establish that the individual defendants were third parties to the” contract. Finally, a determination necessary to deciding his defamation claim “would impermissibly intrude on matters of church organization and polity.” Thus, the court affirmed the orders dismissing the case, which arose from defendant-church’s termination of his employment as its senior pastor. Plaintiff asserted two theories of contract “breach: ‘First, by organizing, announcing, and holding [two meetings] in violation of the Contract. Second, by terminating [plaintiff’s] employment for actions that were well within the scope of his contractual rights.’” The court noted that, under Winkler, the question was “whether adjudicating either theory would require a civil court to resolve ecclesiastical questions reserved to the church. Both theories would require that inquiry, and the trial court properly abstained.” The question of “whether the church and its leadership exceeded their authority in” terminating his employment was not one for the courts. The court found that “even 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.” As to his tortious-interference claim, it was “based on actions the individual defendants allegedly took as church officers, trustees, deacons, or members of church leadership.” He also did not establish that they “acted solely for their own benefit and with no benefit to the church.” As to the defamation claim, the court disagreed “with the trial court’s reasoning that the allegedly defamatory statement was not provable as false.” But it would only be provable as false “if the trial court parsed the agreement and determined which powers belonged to the senior pastor.” He contended the “agreement authorized him to access the church’s bank accounts. Church leadership maintained that it did not. That dispute concerns church polity, and it must be resolved by the church.”