Exceptions to Ecclesiastical Employment Exemptions
In the article titled “Episcopalian In-Fighting Spreads to Montgomery County Courthouse,” published in the March 2009 edition of Upon Further Review, I reported on the employment matter raised by the Rev. David Moyer against the Episcopal Diocese of Pennsylvania regarding his termination by the Diocese from his position as priest in the Church. Suffice it to say here, the Court did not rule in favor of Fr. Moyer as it did not want to entangle itself into an interchurch squabble. However, a recent Pennsylvania case, Mundie v. Christ United Church of Christ, 2009 Pa.Super. 262, has delved into the question of when a court may interject itself into a church employment matter.
In Mundie, the Plaintiff, the Rev. Melvin S. Mundie, was employed as a clergyman at Christ United Church of Christ, the Defendant. Defendant’s governing body, the Consistory, entered into an employment contract with Plaintiff on May 26, 2005. Along with salary, health insurance, and being permitted to reside in the parsonage, the employment contract also specifically stated that the term of Plaintiff’s employment at Defendant would conclude on June 30, 2007, unless otherwise agreed in writing. During the course of Plaintiff’s ministry with Defendant, so-called “church problems” arose between Plaintiff and the congregation that led to, ostensibly, a coup, resulting in the congregation taking over the Consistory and firing Plaintiff on August 28, 2006.
Due to what he perceived as an unlawful termination, Plaintiff brought suit against Defendant for breach of his employment contract. Plaintiff alleged that he was entitled to work for Defendant, collect a salary and health care benefits, and reside in the parsonage until June 30, 2007. Defendant filed preliminary objections stating that Plaintiff’s employment with Defendant was a religious issue into which courts may not intrude.
The Court noted that, as a basic principle, Defendant is correct; a court may not involve itself in what amounts to a religious issue. It is also correct to note that, generally speaking, a religious body’s decisions to hire, fire and prescribe duties to its clergy are constitutionally protected and exempt from a court’s analysis. However, contrarily, a religious body may not avoid a court’s involvement into issues that are exclusively secular. For example, as theMundie Court noted, issues that are not doctrinal issues include “the meaning of agreements on wills, trusts, contracts, and property ownership. These disputes are questions of civil law and are not predicated on any religious doctrine.” Therefore, the narrow issue before theMundie Court was Defendant’s preliminary objections dealing with whether Plaintiff’s employment with Defendant was simply a contractual issue or one that was doctrinal in nature and exempt from court review.
The Court overruled the preliminary objections on the grounds that insufficient discovery had been conducted to shed light on the question of whether Plaintiff’s termination is simply a breach of a secular contract or one that is of more significant doctrinal import. As a light most favorable to the facts plead in Plaintiff’s Complaint must be shed, the Court concluded, for the purposes of the preliminary objections, that Plaintiff’s claims could be exclusively secular. Without an Answer or any discovery, Defendant simply did not have sufficient facts to demonstrate anything to the contrary this early in its litigation. Now that Defendant’s preliminary objections have been overruled, Defendant will have to file an Answer and discovery will presumably ensue. If, through discovery, it is revealed that this matter is a simple breach of contract, Plaintiff’s case may progress; if it is considered to be a matter of doctrine, the Rev. Mundie’s suit will likely face the same fate as that of Fr. Moyer’s.