Banks v. St. Matthew Baptist Church (Lawyers Weekly No. 010-122-13, 12 pp.) (Kaye G. Hearn, J.) (Jean Hoefer Toal, Ch.J., joined by John W. Kittredge, J., dissenting) Appealed from Charleston County Circuit Court (John M. Milling, J.) On writ of certiorari to the Court of Appeals. S.C. S. Ct.
Holding: The defendant-pastor’s allegedly defamatory remarks were made in the context of a congregational meeting, at which the issue of whether plaintiffs would continue as the church’s trustees was discussed; nevertheless, our courts can decide whether the remarks were defamatory pursuant to neutral principles of law without delving into church doctrine or governance.
We affirm our Court of Appeals’ decision. The circuit court erred when it dismissed the trustees’ defamation claim.
The pastor allegedly accused the trustees of deceit and mismanagement of church funds. He urged the congregation to remove the trustees from their positions, and the congregation did so.
Civil courts may hear cases touching upon religious organizations where the dispute may be resolved entirely by neutral principles of law. So long as a court can hear a case without deciding issues of religious law, principle, doctrine, discipline, custom, or administration, the court must entertain jurisdiction.
The pastor allegedly made statements in a church meeting that the trustees failed to inform him of a mortgage on church property, failed to insure church property, mismanaged — and impliedly stole — the church’s money, as well as lied to him. The trustees allege those statements were false and harmed them. As a result, the trustees brought a defamation claim against the pastor.
The truth or falsity of the alleged statements can easily be ascertained by a court without any consideration of religious issues. The pastor admits he made statements to a third party – the congregation. Determining whether the particular statements were made would not require consideration of any religious issues. Determining whether the statements harmed the trustees’ reputations would not require delving into religious issues. Thus, adjudication of the defamation claim would not require any inquiry into or resolution of religious law, principle, doctrine, discipline, custom, or administration.
The only aspect of the trustees’ defamation claim that could be characterized as religious is that the statements were made in a church meeting — a religious setting — in which church governance was discussed.
Defamation is a tort, and the situs of that tort should not dictate the jurisdiction to adjudicate it. A tortfeasor is not shielded from liability simply because he committed his torts within the walls of a church or under the guise of church governance.
Affirmed.
Dissent
(Toal, Ch.J.) The pastor made the statements in question during the course of a congregational meeting while discussing issues inextricably related to church governance. A court cannot possibly exercise jurisdiction over this matter without becoming ensnared in the internal workings of the church’s system of self-governance. The trustees are responsible for more than just the financial well-being of the church; they are also responsible for the spiritual leadership of the congregation.
Our precedents do not stand for the proposition that the courts should involve themselves in a defamation claim arising from statements made during a meeting called for the express purpose of discussing church matters, including the continued service of its trustees in the wake of a financial crisis for the institution.
Because the alleged defamatory remarks center on the relationship of the pastor, his board of trustees, the trustees, and their role in church affairs and spiritual life before a self-governing congregation, I respectfully disagree with an analysis invariably placing civil courts in the position of having to referee this type of ecclesiastical decision-making.