The NLF and another organization have recently filed a brief with the Supreme Court in North American Mission Board of the Southern Baptist Convention v. McRaney. McRaney sued the mission board after his affiliated state board fired him as its lead executive minister, with him claiming that the national board had expressed disapproval of him and so had precipitated his discharge. The Fifth Circuit said the case could proceed and that the district court was to determine whether there was a “valid religious reason” for the minister’s firing. The decision is found at 966 F.3d 346 (5th Cir. 2020).
The case presents two important issues concerning the “church autonomy doctrine,” which provides that courts should not interfere with the inner workings of the administration of religious organizations. First, the circuit court relied on the less hierarchical structure of the Southern Baptists, with each component being an independent legal entity, although associated. But the church autonomy doctrine cannot depend on whether a church has a “high” or “low” organizational structure. Otherwise, the law would give preference to one type of religious organization over another.
Second, the courts have neither the authority nor the competence to determine what is and what is not a “valid religious reason.” One of the principal purposes of the church autonomy doctrine is to keep secular judges out of the business of making just such decisions. A firm line on this is especially needed today, as the doctrines and ethical positions of many religions are out of favor with society and judges alike. The Supreme Court will likely decide whether to review the case before adjourning for the summer recess.
