On May 4, 2007, the North Carolina Supreme Court issued an opinion defining the extent that North Carolina courts may, consistent with the First Amendment to the Constitution of the United States, resolve internal church disputes.  The decision affirms a long history of jurisprudence under the First Amendment that those people in leadership positions within churches, not the courts, are best suited to decide how the churches should be run.  The Court's opinion also will serve as a stern warning to trial courts that they may not, under any circumstance, entertain claims from church members that involve religious doctrine and practice.

The case, Harris v. Matthews, began when a small number of church members filed suit against the church's pastor, trustee, and administrative employee.  The plaintiffs alleged that the defendants misappropriated church funds, breached their fiduciary duties to the church, and participated in a conspiracy to injure the church.  At the heart of the plaintiffs' claims were allegations that certain expenditures made by the defendants were not in furtherance of any valid church purpose.

Poyner & Spruill attorneys Joshua B. Durham and Steven A. Rowe represented the church's pastor, and they moved to dismiss all claims for two reasons.  First, in order to determine whether a particular expenditure was pursuant to a valid church purpose, the trial court would first have to define what the purpose of the church is.  Poyner & Spruill contended this violated the First Amendment's prohibition that government shall not become excessively entangled in religious matters.  Second, Poyner & Spruill contended that the church's governing body, to which the business affairs of the church were entrusted, had reviewed the expenditures at issue and resolved the matter.  Second-guessing the decision of that body would violate the First Amendment's free exercise of religion clause.

The trial court denied the motion to dismiss, and Poyner & Spruill immediately appealed.  The North Carolina Court of Appeals dismissed the appeal, holding that the appeal was premature, as no trial had been conducted.  Confident that the First Amendment barred the plaintiffs' claims and that any further exercise of jurisdiction by the trial court would only entangle the court in the inner workings of the church, Poyner & Spruill petitioned the North Carolina Supreme Court to review the matter.  In December, 2005, the Supreme Court remanded the matter to the Court of Appeals for a more thorough consideration of the issues.  In February, 2006, the Court of Appeals again dismissed the appeal. 

Remaining determined that their client's cause should prevail, Poyner & Spruill again petitioned the North Carolina Supreme Court to resolve the appeal.  On January 8, 2007, the Court held oral arguments, and Joshua B. Durham argued before the justices that the First Amendment prohibited the trial court from resolving the plaintiffs' claims.   

In finding for Poyner & Spruill's client, the Court held that the pastor did have a right to immediately appeal the denial of the motion to dismiss, despite the two decisions by the Court of Appeals to the contrary.  The Court went on to hold that the trial court could not resolve the plaintiffs' claims without becoming entangled in religious matters.  Specifically, the Court said "in order to address plaintiffs' claims, the trial court would be required to interpose its judgment as to both the proper role of these church officials and whether each expenditure was proper in light of [the church's] religious doctrine and practice, to the exclusion of the judgment of the church's duly constituted leadership. This is precisely the type of ecclesiastical inquiry courts are forbidden to make." The Court concluded:  "once it became clear that no neutral principles of law existed to resolve plaintiffs' lawsuit, continued involvement by the trial court became unnecessary and unconstitutional."

If you have any questions about this case, please contact Josh Durham at 704.342.5284 or jdurham@poynerspruill.com or Steve Rowe at 252.972.7108 or srowe@poynerspruill.com.