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.