McRaney v. N Amer Mission Bd
Split Score
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Case Summary
Disposition
Affirmed
A former Baptist convention executive, Will McRaney, sued the North American Mission Board for tortious interference, defamation and related torts after his employment was terminated. The Fifth Circuit held that adjudicating those claims would impermissibly entangle the courts in ecclesiastical matters and that the church-autonomy doctrine (including the ministerial exception) bars the suit; it therefore affirmed summary judgment for NAMB while vacating the district court’s characterization of the bar as jurisdictional.
Circuit Split Identified
Legal Issue
Whether the First-Amendment church-autonomy doctrine is a Rule 12(b)(1) jurisdictional bar or an affirmative merits defense raised under Rule 12(b)(6).
Circuit Positions
Church-autonomy is a jurisdictional bar; civil courts lack subject-matter jurisdiction over such suits.
Church-autonomy is a merits-based constitutional immunity that operates as an affirmative defense, properly raised under Rule 12(b)(6).
Conflict Summary
Some circuits characterize church-autonomy as depriving federal courts of subject-matter jurisdiction, resulting in without-prejudice dismissals under Rule 12(b)(1); others treat it as a constitutional immunity/affirmative defense that must be resolved on the merits under Rule 12(b)(6).