Case Law Pfeil v. St. Matthews Evangelical Lutheran Church of the Unaltered Augsburg Confession of Worthington

Pfeil v. St. Matthews Evangelical Lutheran Church of the Unaltered Augsburg Confession of Worthington

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Zorislav R. Leyderman, The Law Office of Zorislav R. Leyderman, Minneapolis, MN, for appellant.

Ken D. Schueler, Jennifer M. Peterson, Dunlap & Seeger, P.A., Rochester, MN; and Timothy J. O'Connor, William L. Davidson, Lind, Jensen, Sullivan & Peterson, P.A., Minneapolis, MN, for respondents.

Mark R. Bradford, Steven P. Aggergaard, Bassford Remele, Minneapolis, MN; and Sherri C. Strand, Mark Sableman, Anthony F. Blum, Thompson Coburn, LLP, Saint Louis, MO, for amicus curiae The Lutheran Church–Missouri Synod.

OPINION

ANDERSON, Justice.

In this case, we are presented with the question of whether pastors and their church can be held liable for statements the pastors made about a parishioner during formal church disciplinary proceedings. Appellants LaVonne and Henry Pfeil allege that they were defamed by the pastoral staff of St. Matthew Lutheran Church1 during two church disciplinary proceedings that were held for the purpose of excommunicating the Pfeils from St. Matthew. The district court dismissed the Pfeils' claims with prejudice on First Amendment grounds, and the court of appeals affirmed. Because the First Amendment to the United States Constitution protects the right of a religious organization to make autonomous decisions regarding church discipline and membership, we affirm the district court's dismissal of the claims.

I.

Prior to 2011, LaVonne and Henry Pfeil were longstanding members of St. Matthew.2 St. Matthew, in turn, is a member of the Lutheran Church–Missouri Synod. On August 22, 2011, the Pfeils received a letter signed by St. Matthew's pastors, respondent Thomas Braun ("Braun") and respondent Joe Behnke ("Behnke"). The letter contained several allegations regarding the Pfeils' conduct over the preceding two years, but focused on complaints that the Pfeils had been engaged in "slander and gossip" against the leadership and ministry of the congregation. In addition to criticizing the Pfeils' behavior, the letter advised the Pfeils that they had excommunicated themselves from St. Matthew and informed the Pfeils that their church membership had been terminated.

Subsequent to the August 22 letter, the Lutheran Church–Missouri Synod advised the leadership of St. Matthew to hold a "special voters' meeting" so that the congregation could vote to affirm or reject the excommunication decision. The Pfeils and approximately 89 members of St. Matthew attended the special voters' meeting, which was held on September 25, 2011. Braun addressed the meeting, reading from a set of prepared remarks, and published the August 22 letter to those present at the meeting. According to the Pfeils, Braun's remarks and the August 22 letter contained several defamatory statements, including:

• The Pfeils were actively involved in slander, gossip, and speaking against Braun and his wife, Behnke, and the St. Matthew Board of Elders.
• The Pfeils had intentionally attacked, questioned, and discredited the integrity of Braun, Behnke, and other St. Matthew church leaders.
• Other people had observed the Pfeils display anger and disrespect toward Braun.
• The Pfeils had publicly engaged in "sinful behavior" inside and outside St. Matthew.
• The Pfeils had engaged in behavior unbecoming of a Christian.
• The Pfeils had engaged in a "public display of sin."
• The Pfeils had refused to meet for the purpose of confession and forgiveness.
• The Pfeils had "refused to show respect" toward servants of God and St. Matthew church leadership.
• The Pfeils had led other people into sin.
• The Pfeils had engaged in slander and gossip and had refused to stop engaging in slander and gossip.
• The Pfeils had refused to follow the commands and teachings of God's word.

After Braun's remarks, ballots were distributed to the members of St. Matthew who were present at the meeting, and the members voted to affirm the pastors' decision to terminate the Pfeils' membership at St. Matthew. Subsequently, in March 2012, a Missouri Synod panel held a hearing to reconsider the Pfeils' excommunication. The Pfeils allege that during the Synod hearing, Behnke falsely claimed that the Pfeils had recently accused Behnke of stealing money from St. Matthew. The Synod panel also affirmed the Pfeils' excommunication.

On August 16, 2013, LaVonne Pfeil brought a lawsuit on behalf of herself and Henry Pfeil, asserting claims for defamation and negligence against St. Matthew, Braun, and Behnke (collectively respondents).3 On December 24, 2013, respondents filed a motion to dismiss for lack of subject matter jurisdiction pursuant to Minn. R. Civ. P. 12.02(c). Respondents argued that the Pfeils' claims would cause the district court to become excessively entangled with religion and that the claims were therefore barred by the First Amendment to the United States Constitution under the "ecclesiastical abstention doctrine."

After resolving Henry Pfeil's claims on other grounds,4 the district court concluded that the First Amendment deprived the court of jurisdiction to adjudicate LaVonne Pfeil's remaining claims and dismissed the case with prejudice. The Pfeils appealed the district court's ruling and the court of appeals affirmed with respect to the First Amendment issue, concluding that the First Amendment barred all of the Pfeils' claims.5 Pfeil v. St. Matthews Evangelical Lutheran Church, No. A14–0605, 2015 WL 134055, at *3–6 (Minn.App. Jan. 12, 2015). We granted review to clarify our jurisprudence regarding the intersection of the First Amendment and civil claims against religious institutions.

II.
A.

The district court and the court of appeals based their rulings on what they termed the "ecclesiastical abstention doctrine." The legal principle that has come to be known as the "ecclesiastical abstention doctrine" or the "church autonomy doctrine" has its roots in a line of U.S. Supreme Court decisions regarding church property and church schisms. The first, Watson v. Jones, 80 U.S. (13 Wall.) 679, 20 L.Ed. 666 (1872), concerned a dispute over which individuals were entitled to the position of "elder" in a Presbyterian church in Kentucky. Id. at 714. Rather than evaluate the merits of the parties' arguments regarding church doctrine, the Court deferred to the ruling of the Presbyterian General Assembly, which did not recognize the individuals in question as elders, and indicated the lower courts should have exercised the same deference. See id. at 732–34. The Court viewed judicial review of ecclesiastic tribunals as striking at the very heart of religious freedom and held that allowing civil review would "deprive [religious] bodies of the right of construing their own church laws ... and would, in effect, transfer to the civil courts where property rights were concerned the decision of all ecclesiastical questions." Id. at 733–34. The essence of the Court's holding is captured in a now-famous quotation:

The right to organize voluntary religious associations to assist in the expression and dissemination of any religious doctrine, and to create tribunals for the decision of controverted questions of faith within the association, and for the ecclesiastical government of all the individual members, congregations, and officers within the general association, is unquestioned. All who unite themselves to such a body do so with an implied consent to this government, and are bound to submit to it. But it would be a vain consent and would lead to the total subversion of such religious bodies, if any one aggrieved by one of their decisions could appeal to the secular courts and have them reversed. It is of the essence of these religious unions, and of their right to establish tribunals for the decision of questions arising among themselves, that those decisions should be binding in all cases of ecclesiastical cognizance, subject only to such appeals as the organism itself provides for.

Id. at 728–29.

The U.S. Supreme Court strengthened the doctrine announced in Watson when it decided Serbian Eastern Orthodox Diocese for the United States of America & Canada v. Milivojevich, 426 U.S. 696, 96 S.Ct. 2372, 49 L.Ed.2d 151 (1976).6 In deciding that the Illinois Supreme Court had violated the First Amendment when it reinstated a defrocked bishop, the Milivojevich Court held that "where resolution of the disputes cannot be made without extensive inquiry by civil courts into religious law and polity, the First and Fourteenth Amendments mandate that civil courts shall not disturb the decisions of the highest ecclesiastical tribunal within a church of hierarchical polity, but must accept such decisions as binding on them, in their application to the religious issues of doctrine or polity before them." Id. at 709, 96 S.Ct. 2372.

But the autonomy granted to religious institutions by the First Amendment is not boundless. The U.S. Supreme Court has repeatedly emphasized that certain situations allow courts to use "neutral principles of law" to resolve controversies involving religious institutions and their parishioners. Jones v. Wolf, 443 U.S. 595, 602–05, 99 S.Ct. 3020, 61 L.Ed.2d 775 (1979) (approving of the "neutral principles of law" approach as "consistent with the [First Amendment]" and stating that "[w]e cannot agree [with the dissent] that the First Amendment requires the States to adopt a rule of compulsory deference to religious authority in resolving church property disputes, even where no issue of doctrinal controversy is involved"); Presbyterian Church in the U.S. v. Mary Elizabeth Blue Hull Mem'l Presbyterian Church, 393 U.S. 440, 449, 89 S.Ct. 601, 21 L.Ed.2d 658 (1969) (suggesting that courts could resolve church property disputes if they applied "neutral principles of law"). Indeed, we applied the...

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In re Lubbock
"...repeated outside that context." Id. at 937 n.12 (emphasis added).Similarly, in Pfeil v. St. Matthews Evangelical Lutheran Church of the Unaltered Augsburg Confession of Worthington , 877 N.W.2d 528 (Minn. 2016), the Minnesota Supreme Court dismissed two excommunicated parishioners' defamati..."
Document | U.S. Court of Appeals — Fifth Circuit – 2020
McRaney v. N. Am. Mission Bd. of the S. Baptist Convention, Inc.
"...("[T]he ecclesiastical-abstention doctrine is an affirmative defense."); Pfeil v. St. Matthews Evangelical Lutheran Church of Unaltered Augsburg Confession of Worthington , 877 N.W.2d 528, 534–35 (Minn. 2016) (reversing course on previous holding and noting " Hosanna-Tabor leads us to concl..."
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"...Star & Tribune Co., 390 N.W.2d 437, 441 (Minn. Ct. App. 1986) (citations omitted); see also Pfeil v. St. Matthews Evangelical Lutheran Church, 877 N.W.2d 528, 546 (Minn. 2016) (citation omitted) (holding that expressions of opinion are not actionable). Like New Jersey, Minnesota courts embr..."
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1 books and journal articles
Document | Vol. 98 Núm. 3, March 2023 – 2023
THE LIMITS OF CHURCH AUTONOMY.
"...2018); Pfeil v. St. Matthews Evangelical Lutheran Church of the Unaltered Augsburg Confession of Worthington, Nobles Cnty., Minn., 877 N.W.2d 528, 541 (Minn. 2016); Hiles v. Episcopal Diocese of Mass., 773 N.E.2d 929, 936-37 (Mass. 2002); Paul v. Watchtower Bible & Tract Soc'y of N.Y., ..."

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1 books and journal articles
Document | Vol. 98 Núm. 3, March 2023 – 2023
THE LIMITS OF CHURCH AUTONOMY.
"...2018); Pfeil v. St. Matthews Evangelical Lutheran Church of the Unaltered Augsburg Confession of Worthington, Nobles Cnty., Minn., 877 N.W.2d 528, 541 (Minn. 2016); Hiles v. Episcopal Diocese of Mass., 773 N.E.2d 929, 936-37 (Mass. 2002); Paul v. Watchtower Bible & Tract Soc'y of N.Y., ..."

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In re Lubbock
"...repeated outside that context." Id. at 937 n.12 (emphasis added).Similarly, in Pfeil v. St. Matthews Evangelical Lutheran Church of the Unaltered Augsburg Confession of Worthington , 877 N.W.2d 528 (Minn. 2016), the Minnesota Supreme Court dismissed two excommunicated parishioners' defamati..."
Document | U.S. Court of Appeals — Fifth Circuit – 2020
McRaney v. N. Am. Mission Bd. of the S. Baptist Convention, Inc.
"...("[T]he ecclesiastical-abstention doctrine is an affirmative defense."); Pfeil v. St. Matthews Evangelical Lutheran Church of Unaltered Augsburg Confession of Worthington , 877 N.W.2d 528, 534–35 (Minn. 2016) (reversing course on previous holding and noting " Hosanna-Tabor leads us to concl..."
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E. Coast Test Prep LLC v. Allnurses.com, Inc., CIVIL NO. 15–3705 (JRT/JSM)
"...Star & Tribune Co., 390 N.W.2d 437, 441 (Minn. Ct. App. 1986) (citations omitted); see also Pfeil v. St. Matthews Evangelical Lutheran Church, 877 N.W.2d 528, 546 (Minn. 2016) (citation omitted) (holding that expressions of opinion are not actionable). Like New Jersey, Minnesota courts embr..."
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State v. Huber
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Friends to Restore St. Mary's, LLC v. Church of Saint Mary, A18-2107
"...its roots in a line of U.S. Supreme Court decisions regarding church property and church schisms." Pfeil v. St. Matthews Evangelical Lutheran Church , 877 N.W.2d 528, 532 (Minn. 2016). In Pfeil , the Minnesota Supreme Court clarified that the ecclesiastical abstention doctrine is not a matt..."

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