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Weems v. Ass'n of Related Churches
THIS CAUSE is before the Court on Defendants' Motion to Dismiss for Lack of Jurisdiction or, Alternatively, Motion for More Definite Statement and Supporting Memorandum of Law (Doc. 28; Motion) filed on August 28, 2023. In the Motion Defendants seek dismissal of Plaintiffs' Complaint & Demand for Jury Trial (Doc. 1; Complaint) based on the ecclesiastical abstention doctrine. Motion at 1. In the alternative, Defendants ask the Court to “order a more definite statement and require that Plaintiffs replead the Complaint.” Id. at 24. Plaintiffs have filed a response in opposition to the Motion. See Plaintiffs' Response in Opposition to Defendants' Motion to Dismiss or for More Definite Statement (Doc. 35; Response), filed September 25, 2023.[1]Accordingly, this matter is ripe for review. For the reasons that follow, the Court finds that the Motion is due to be granted to the extent that the Court will strike the Complaint as a shotgun pleading and direct Plaintiffs to file an amended complaint.
Plaintiffs Charles Stovall Weems (“Pastor Weems”) and Kerri Weems are co-founders of Celebration Church. Complaint at 1, 7. Before he resigned from his position with the Church in April 2022, Pastor Weems had been Celebration Church's Senior Pastor and CEO since its founding in 1998. See id. ¶¶ 27-29. Plaintiffs Celebration Global, Inc., Honey Lake Farms, Inc., NorthStream Management Group, LLC, and Weems Group, LLC., are business entities Pastor Weems and Kerri Weems created to “house and fund Celebration Church's significant administrative and personnel operations” and to support Pastor Weems's missionary work. See Id. ¶¶ 35-38. Defendants are the Association of Related Churches (“ARC”), which is a “cooperative of independent churches from different denominations,” id. ¶ 39, ARC's co-founder Chris Hodges, id. ¶ 47, ARC's Executive Director Dino Rizzo, id. ¶ 52, and ARC's “founding board member” John Seibeling, id. ¶ 53. Rizzo and Seibeling also served as “Overseer[s] at Celebration Church until September 2021.” Id. ¶¶ 52-53.
In the Complaint, Plaintiffs assert that Defendants engaged in an “unlawful conspiracy” to “protect and expand their church growth business interests and endeavors and the substantial income they generate by destroying Plaintiffs and eliminating them as perceived threats and competitors,” including by “engineering a takeover at Celebration Church of Jacksonville, Inc.” Id. ¶ 1. Among other allegations, Plaintiffs assert that Defendants orchestrated a “sham ‘investigation'” within Celebration Church to frame Pastor Weems for embezzlement. See id. ¶ 125. According to Plaintiffs, this caused Celebration Church to “avoid paying Plaintiffs the benefits [it] had already agreed to provide,” allowed Defendants to “install leadership [they] could control” within Celebration Church, and eliminated “Honey Lake Farms as competition” for a similar entity developed by Hodges and Rizzo.[3]Id. ¶¶ 95, 126. Plaintiffs plead two counts in their 182-paragraph Complaint. In Count I, Plaintiffs assert a claim for tortious interference with “Plaintiffs' advantageous contractual and business relationships.” See id. ¶¶ 166-173. In Count II, Plaintiffs assert a claim for conspiracy based on all the same facts. See id. ¶¶ 174-182. Defendants seek dismissal of both Counts. See generally Motion.
In the Motion, Defendants first argue that the ecclesiastical abstention doctrine prevents the Court from adjudicating Plaintiffs' claims. See id. at 1321. In the alternative, Defendants assert that the Complaint is an impermissible shotgun pleading. See id. at 21-23. As explained below, Defendants' first argument fails for the same reason their second one succeeds: because the Complaint is a shotgun pleading, the Court lacks sufficient information to determine the applicability of the ecclesiastical abstention doctrine to any of Plaintiffs' claims.
In general, pursuant to the ecclesiastical abstention doctrine, “[c]ivil courts lack jurisdiction to entertain disputes involving church doctrine and polity” unless the dispute can be resolved “under neutral principles” of law without “consideration of religious doctrinal matters.” See Rutland v. Nelson, 857 Fed.Appx. 627, 628 (11th Cir. 2021) ).[4] Defendants assert that resolving Plaintiffs' claims would require “excessive judicial entanglement” with Celebration Church's internal governance and would require the Court to answer several “manifestly ecclesiastical questions.” Motion at 14-20. For this reason, Defendants contend that the Court cannot evaluate the “causation and damages elements of Plaintiffs' claims” without violating the First Amendment. See id. at 18. In response, Plaintiffs assert that Defendants fail to analyze the “relationships amongst these parties and nature of the claims at issue” in this case, as opposed to those in related state-court litigation against Celebration Church itself.[5] See Response at 3. Accordingly, Plaintiffs argue that Defendants “fail to meet th[eir] burden” of showing that the dispute cannot be decided based on neutral principles of secular law.[6]See id. at 8.
For some events and business relationships Plaintiffs describe in the Complaint, Defendants' arguments likely are well-taken.[7]But Plaintiffs describe (or allude to) many business relationships in the Complaint, see, e.g., Complaint ¶¶ 102-106, and the Court is unable to determine which relationships, acts, or omissions form the basis of their tortious interference claims.[8]Without allegations that identify which actions by which Defendants harmed which Plaintiff and which of that Plaintiffs relationships with which entities, the Court cannot determine whether resolution of each Plaintiffs' claims requires consideration of religious doctrinal matters as opposed to a straightforward application of secular law. For example, it is unclear which claims would require the Court to determine how Celebration Church began its investigation into Pastor Weems, interpret the church's financial policies and bylaws, or weigh the effect of the investigation report “on [Celebration Church's] board members as compared to the effects of' other religious disagreements.[9]See Motion at 14, 18. Accordingly, the Court is unable to determine whether and to what extent the claims in this case require the inquiries which Defendants argue would be impermissible.
Barmapov, 986 F.3d at 1324-25 (quoting Weiland, 792 F.3d at 1321-23). Defendants contend that the Complaint falls into each of these four categories. Motion at 22. At least regarding the second, third, and fourth categories, Defendants are correct.[11]
As to the second category, the Complaint is replete with conclusory, vague allegations.[12]See, e.g., Complaint ¶ 24 (); id. ¶¶ 58-59 (); id. ¶ 68 (...
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