In Second Episcopal Dist. African Methodist Episcopal Church v. Prioleau, Case No. 11-CV-382, 2012 WL 3243190 (D.C. App. Aug. 9, 2012), the court ruled that the First Amendment does not bar a former pastor's breach of contract action against her church for failing to pay money the church admitted it owed her under the last of a series of year-long employment contracts. The court determined that resolving the former pastor's claims would not require the court to entangle itself in church doctrine and that the relief the pastor requested was exclusively monetary, not reinstatement, so that her case would have no effect on the church's appointment of a leader. Therefore, the court ruled it could decide the case employing a "neutral principles of law" analysis and remanded the case with a warning that the court should grant summary judgment if "it becomes apparent ... that this dispute does in fact turn on matters of doctrinal interpretation or church governance...."

In Crymes v. Grace Hope Presbyterian Church, Inc., Case No. 2011-CA-000746-MR, 2012 WL 3236290 (Ky. App. Aug. 10, 2012), the court ruled the same way, that a former pastor's claim for unpaid wages and benefits for work previously performed under an employment contract is not ecclesiastical and is reviewable by the court. The court explained, "[W]hile termination of a pastor constitutes an ecclesiastical matter, breach of contract claims for wages or benefits accrued during the pastor's term of employment and prior to his termination do not constitute ecclesiastical matters."