In Smith v. Jamison, 36 Fla. L. Weekly D2054a (Fla. 1st DCA Sept. 16, 2011), a dispute arose over how the First Baptist Church of Micanopy, Inc. was to be governed. The parties involved had divergent beliefs about church governance, which eventually led to the ousted group suing the church and its pastor for breach of fiduciary duty. The plaintiffs claimed that the defendants acted unlawfully by failing to follow the procedures set forth in the church’s articles of incorporation and bylaws for removing individuals as members and officers of the church, electing directors and amending the articles and bylaws. However, the circuit court concluded that it did not have jurisdiction over what it deemed “an ecclesiastical dispute.”
The plaintiffs alleged that the trial court erred in finding the matter to be an ecclesiastical dispute over which the court had no jurisdiction. They argued that the breach of fiduciary duty claim was purely secular, because the issue was whether the church, in removing certain members, electing new directors and changing its governing documents, contravened chapter 617, Florida Statutes. Furthermore, because the church was incorporated as a nonprofit entity under chapter 617, it was required to abide by the statutory provisions requiring certain corporate actions to be taken in accordance with the entity’s articles of incorporation or bylaws.
The First District Court of Appeal agreed with the circuit court that the essential dispute in this case was over how the church should govern itself, which was a religious matter. The court further explained that any inquiry into whether the church adhered to its bylaws in excluding members necessarily entangled the court in religious matters protected by the First Amendment. Finally, the court held that exercising jurisdiction in this instance would be tantamount to intervening on behalf of a group espousing particular doctrinal beliefs.