North American Mission Board of the Southern Baptist Convention Inc. v. McRaney

In June 2015, Will McRaney was terminated from his position as the executive director of the Baptists Convention of Maryland/Delaware "BCMD" after holding this position for two years. Over a year after he was fired, McRaney filed a lawsuit in April 2017 against the North American Board "NAMB," as he claimed he was wrongfully terminated after an argument over collaborative regional mission efforts. McRaney alleged that the NAMB had harmed his career as an executive director, harmed his ministry, and caused him emotional distress. NAMB says that McRaney had turned into a "dysfunctional ministry partner" as the executive director, and denies interfering with McRaney's employment situation. In fact, NAMB is under the impression that he voluntarily resigned from the BCMD and agreed to a severance package. NAMB also says that McRaney's actions caused the BCMD to violate their Strategic Partnership Agreement with the NAMB. McRaney allegedly interfered with BCMD's religious obligations, thus NAMB was entitled to notify the BCMD that they were terminating their partnership with them if these circumstances continued.

On April 22, Senior Judge Glen Davidson of the U.S. District Court Northern District of Mississippi originally took on, but soon dismissed this case. Judge Davidson dismissed the case due to "lack of subject matter jurisdiction," as he said that deciding on this case would require the court to rule on religious elements that would constitute too much interference between the government and the Church. Judge Davidson cited the "ecclesiastical abstention doctrine" in his reasoning which is a constitutional principle that prohibits the court from resolving matters inherently religious in nature. 

In July 2020, the 5th U.S. Circuit Court of Appeals overturned the decision made in the lower court, however they could not determine if the ecclesiastical abstention doctrine applied. They instead said that the uncertainty surrounding the facts of this case was what caused them to rule in favor of McRaney. NAMB appealed this decision to the Supreme Court and said they would allow the federal court to explore the religious freedom protections afforded by ministries under the First Amendment.

The facts of this case are confusing, similar to a "he said, she said" scenario. However, the main issues are similar to what we had just discussed in class on Monday. The two questions at hand are: Can a secular court judge a minister's employment-related state-low tort claims against a religious organization using neutral principles? and Does the First Amendment prevent the judgement of a minister's employment-related state-law tort claim only when brought against the minister's employer? 

I side with the NAMB in this case. I believe that churches and ministers need to be protected from government interference, as the church and state are two separate entities. NAMB should be able to create or dissolve partnerships how they see fit, as cooperations between organizations and churches is a right protected by the First Amendment. NAMB should be able to work with BCMD in order to put into place a ministry strategy without the threat of government intervention. As discussed in the Hosanna-Tabor case, the Supreme Court has previously ruled down on the "ministerial exception", which helps to prevent state interference in churches. The church autonomy doctrine spelled out in Hosanna-Tabor also ensures that Church authorities are given the right to select and control who they want as a minister and that this is the Church and the Church alone's decision. Furthermore, in Our Lady of Guadalupe, the Supreme Court ruled that "courts are bound to stay out of employment disputes involving those holding certain important positions with churches and other religious institutions." Given the arguments that were made in the majority decision of each of these cases, I believe that NAMB should be allowed to determine who they foster relationships with based on each cooperation's minister (in this case BCMD's executive director which was Minister McRaney) and that the court should not intervene on Church's decisions.

One issue here that the opposing side might make is that McRaney was not an employee of NAMB therefore this case is about McRaney's complaint of external actions towards separate organizations. This means that if NAMB told BCMD to fire McRaney (which McRaney claims it true) then it wold not fall under the ecclesiastical abstention doctrine and a civil court can make a decision and have jurisdiction in this case. This would then distinguish this case from Hosanna-Tabor and Our Lady of Guadalupe. However, because I do not believe McRaney's claim that the NAMB directly told BCMD to fire him, I would argue against this point that could be made in McRaney's favor.

This case is important in reaffirming the rights afforded to religious groups by the First Amendment. Although there is some confusion in the details of this case, in Hosanna-Tabor, the Supreme Court unanimously agreed that the First Amendment must "give special solicitude to the rights of religious organizations." In order to affirm their decision and continue to reinforce this standard, the Supreme Court should rule in favor of the NAMB.