The ecclesiastical abstention doctrine (arising from the First Amendment); Winkler v Marist Fathers of Detroit; First Protestant Reformed Church of Grand Rapids v DeWolf; Defamation; False-light invasion of privacy; Perrone v Bugarin (Unpub); Intentional infliction of emotional distress (IIED); Concert of action; Breach of contract; American Muslim Diversity Association (AMDA)

Holding that the trial court correctly ruled that the ecclesiastical abstention doctrine barred plaintiff-Ahmed’s breach of contract and tort claims, the court affirmed summary disposition for defendants. He worked for defendant-AMDA as an assistant Imam until its board of trustees terminated the contractual relationship after domestic violence allegations were made against him. He asserted claims for breach of contract, defamation, false-light invasion of privacy, IIED, and concert of action. On appeal, the court concluded the “trial court correctly determined that resolution of Ahmed’s breach-of-contract claim would require [it] 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. While the board found “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.” As to his tort claims, the court found that analyzing the “defamation and false-light invasion of privacy claims would require determining the truth or falsity of defendants’ alleged statements calling into question whether Ahmed was qualified to perform the duties of an assistant Imam. [He] alleged that defendants falsely stated he was not so qualified and lacked the character required and expected of an assistant Imam.” The 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.” Plaintiff’s IIED and concert of action claims also failed because they involved “evaluating defendants’ decisions and method of reaching” them.