MN Supreme Court: Church schism none of our business

A divided Minnesota Supreme Court on Wednesday settled the question of whether the state’s courts have any business weighing in on claims of defamation made by church officials while excommunicating parishioners.

It ruled in the case of LaVonne Pfeil and the late Henry Pfeil, who charged that pastors at St. Matthew Evangelical Lutheran Church in Worthington, Minn., defamed them during excommunication processes in 2011.

Today, the Supreme Court said the First Amendment does not give the courts the authority to intervene, upholding two lower courts.

The Pfeils objected to a letter church officials sent to their flock in which pastors alleged the couple engaged in “slander and gossip” against the leadership and ministry of the congregation, which, among other things, alleged the couple accused pastors of stealing money.

They claimed they were defamed by allegations made against them in the letter and at a meeting of 89 members of the church.

  • Other people had observed the Pfeils display anger and disrespect toward Braun.
  • The Pfeils had publicly engaged in “sinful behavior” inside and outside St.Matthew.
  • The Pfeils had engaged in behavior unbecoming of a Christian.
  • The Pfeils had engaged in a “public display of sin.”
  • The Pfeils had refused to meet for the purpose of confession and forgiveness.
  • The Pfeils had “refused to show respect” toward servants of God and St. Matthew church leadership.
  • The Pfeils had led other people into sin.
  • The Pfeils had engaged in slander and gossip and had refused to stop engaging in slander and gossip.
  • The Pfeils had refused to follow the commands and teachings of God’s word.

“A court cannot overturn the decisions of governing ecclesiastical bodies with respect to purely ecclesiastical concerns, such as internal church governance or church discipline,” Justice G. Barry Anderson wrote in today’s opinion.

Although other statements seem more secular in nature, it would certainly be difficult to differentiate between secular and religious statements, especially when the context in which the statements were made was clearly religious.

A statement-by-statement analysis would be, at best, a difficult endeavor and, at worst, a court might be forced to interpret doctrine just to determine whether or not a statement had a religious meaning.

It is precisely this sort of complicated and messy inquiry that we seek to avoid by prohibiting courts from becoming excessively entangled with religious institutions.

Anderson said if the court interfered in the schism, “it would both excessively entangle the court with religion and unduly interfere with the ability of religious organizations to make decisions regarding membership and internal discipline.”

In a dissent, Justice David Lillehaug, joined by Chief Justice Lorie Gildea, said the decision gives religious authorities an absolute right to defame parishioners. “No matter how false and malicious the statement, and no matter how much the victim is damaged, there is no remedy whatsoever in Minnesota’s courts,” he wrote.

But there are clear instances in which we can apply neutral principles of state defamation law to adjudicate defamation claims without excessive entanglement. Imagine a religious disciplinary proceeding in which a member has been charged with teaching false doctrine in the Sunday school.

Plainly, we could not adjudicate any dispute regarding “false doctrine.” But, assume that, in response, the member says, maliciously and without a shred of truth: “The charge that I’m harming the Sunday school is ironic, given that the minister regularly sexually assaults the kids in the class.”

As is true of many vicious accusations, inevitably such a defamatory statement would spread like wildfire through the religious organization and into the community, causing great injury. Applying the Odenthal framework, a district court could likely use neutral principles of state defamation law to adjudicate the minister’s defamation claim without excessive entanglement.

“I lost my church, I lost my husband, lost my reputation, lost a lot of money,” Mrs. Pfeil, 79, told the Star Tribune after the Supreme Court heard arguments in the case last fall. “I can go to a grocery store. If people see me, they turn around with their cart. I used to know everybody. Now I have no friends.”

She said the case likely started in a church kitchen during a 2010 funeral when someone started swearing because coffee grounds got into the coffee. She was blamed for the obscenities but insists it wasn’t her.

  • jon

    “the decision gives religious authorities an absolute right to defame parishioners.”

    What about those of us who aren’t Parishioners of any given church?
    Can they openly defame us?
    Or at that point are they individuals instead of religious authorities?

    Would a certificate of ordination from the universal life church give me the authority to slander and libel anyone with no real repercussions?

    • I imagine it depends on how the defamation is communicated. In this case, the communication was strictly inside the church.

      • tboom

        >>In this case, the communication was strictly inside the church.<<

        Technically (legally) true … but not really, especially in a small town.

        • jon

          Certainly not true any more, There is a list above in this very article of the statements that were made against them.
          But I suspect that the church can’t be held liable for some one bringing charges against them.

          • tboom

            >>But I suspect that the church can’t be held liable for some one bringing charges against them.<<

            Right. The communication in meeting and letter was between the church (council/authorities) and the church (members). My point is the charges almost certainly became “public” because of rumor and innuendo, in a small town rumor and innuendo is an efficient form of communication (and very Christian). Of course the legal action resulted in the charges being published for real.

      • jon

        So I’d be able to slander and defame anyone I want so long as I keep it with in whatever church I’m declared as an authority in… I could probably work with that. 😉
        “I’ve got some really juicy gossip, but you’ll need to join my church to hear it!”

        Though still, left to wonder how this would play out if it were any organization besides a church (any non-religious organization).

        • Rob

          In such cases, the Establishment Clause would not be a factor, so there’s that.

      • kennedy

        Content also matters in this case. The ‘slander’ in this case was concerning violation of church rules. The ruling does not give free license to libel or slander.

        • You’ve read the opinion, right?

          • kennedy

            Yeah, I should have been more clear. The shelter from defamation is for church rulings or activities. It gives the church immunity for communication during formal proceedings in the business of the church.

            It does not give immunity based on physical location. If one church member (or leader) defames another person on church property, it can be prosecuted.

  • John

    As I read the list of alleged defamations, I can’t help but wonder which (if any) of them would have any legal standing. Most of them center around the ideas of sin and refusal to show respect to church leadership – things that are entirely subjective and dependent on the definitions of the church, not government.

    Last time I checked, those are pretty subjective claims. The law doesn’t typically deal in “sin,” as far as I know, so it seems like you could accuse anyone of engaging in “sinful behavior,” because that’s a phrase that is completely dependent upon the church in question, and not any sort of generally accepted definition beyond the confines of a specific religion.

    The quickest example I can think of is one that is still a hot button in many places: Many religious groups consider homosexuality a sin, and marriage between two people to be limited to a man and woman. That no longer preclude two people from a civilly recognized marriage, but may still be a sin in the eyes of the church.

    I think it’s right for the court to stay out of church business. Sin is too slippery a concept, and is thrown around too loosely to be able to be considered defamatory.

  • Rob

    It seems like dysfunction is the primary characteristic of many church leadership/parishioner situations, such that we’re all better off if the courts deign not to wade into them.

  • Rob

    The Pfeils had refused to meet for the purpose of confession and forgiveness.

    Lutherans being asked to go to confession?

    • Dan

      Missouri Synod.

      • ChrisF

        Ahhhh. I was wondering about that.

  • MarkUp

    Does defamation law make the practice of shunning illegal?

  • Eric

    Hoping these reminders from Paul can inform how Christians are to live together.

    Ephesians 4:1-3 I therefore, a prisoner for the Lord, urge you to walk in a manner worthy of the calling to which you have been called, with all humility and gentleness, with patience, bearing with one another in love, eager to maintain the unity of the Spirit in the bond of peace.

    1 Peter 3:8-9 Finally, all of you, have unity of mind, sympathy, brotherly love, a tender heart, and a humble mind. Do not repay evil for evil or reviling for reviling, but on the contrary, bless, for to this you were called, that you may obtain a blessing.

  • raymarshall

    The State Supreme Court would change their tune quite quickly if someone was excommunicated for being a homosexual!!!!!

    • John

      doubt it. also – that has nothing to do with this.

    • Troll O Matic.

    • Rob

      bzzzzzzt! wrong answer, Sir Troll

  • Mark in Ohio

    Wow, I wasn’t aware that the practice of excommunication occurred in anything other than history texts or third world countries. That it causes people to shun someone outside of church is even more surprising to me. I guess I’ve led a sheltered life. That said, I’ll agree with the comments saying that the courts should avoid getting entangled in internal church politics.

    • Kassie

      Unless the internal church politics involve sheltering child abusers….

      • Mark in Ohio

        Agreed. I should have amended my statement to add “over civil matters”. Criminal offenses are still criminal offenses, at least in this country. I’ve heard that in some countries, churches are sanctuary for all crimes, and that you can’t arrest someone in a church. I’m a bit curious as to how prevalent and strongly observed that restriction is.

  • Al

    “She said the case likely started in a church kitchen during a 2010 funeral when someone started swearing because coffee grounds got into the coffee.”

    CHURCHES. AMIRITE?

  • lindblomeagles

    Obviously, its been a long time since the 1600s, but a man by the name of Roger Williams advocated for the separation of church and state in colonial Massachusetts. When he told his brethren, don’t take land away from Native Americans, HIS church had had enough and banished him from the colony in 1636. RW, however, had a few followers. Together they purchased land from the Narragansett establishing a new colony founded on religious liberty and separation of church and state. That land became Rhode Island. Things again disintegrated for Roger in the colonies, including the one he founded Land hungry colonists and zealous Christian worshippers (mainly Puritans and Quakers) pressed Roger’s beliefs in Rhode Island, until at last King Philip’s War in 1676, a battle between the colonies and Massachusetts area tribes, pushed Roger into the background. He died without a footnote in 1683 accused of being too close to Native Americans. Ironically, Roger’s idea of separation of church and state received an audience in the US about 100 years later. The Founders like his idea so much they placed it in the US Constitution and the Bill of Rights. The moral of the story is this, the Christian Faith remains a nebulous religion, practiced by many Americans differently; dividing itself into other Christian churches each time one of its leaders tries to lead the old church in another direction.

  • bill

    This is why people are better off just avoiding religion altogether and sticking with this little thing called “reality” instead. Clergy in Minnesota have been granted a legal license to ruin people’s lives with lies with no possibility of legal recourse against them. Who on earth is ignorant enough to put themselves at that kind of risk? Can anyone honestly say the Catholic church in particular has demonstrated any ethical character or trustworthiness whatsoever in recent history? That’s what I thought….