If the Ecclesiastical Abstention Doctrine and the Ministerial Exception mean anything, at the least they preclude judicial inquiry into denominational management or discipline of its own clergy (regardless of by what title they may be known).  In Melendez v Evangelos Kourounis, Slip Op. (NJ App. Div. 2017) a trial court’s summary judgment was affirmed per curiam.  The clergyman established a mission chapel.  He claimed it was with the bishop’s approval.  The bishop denied that it was an approved mission.  The bishop also issued an encyclical in which the clergyman was barred and local clergy were instructed to advise parishioners not to go to the mission chapel.  The clergyman sued for defamation but without doubt that required inquiry into the scope of denominational authority which is typically ecclesiastically defined.  On that basis the trial court dismissed the case and on that basis the appellative division affirmed.

The denomination appeared to be hierarchical.  However, that might not matter.  If the denomination has given itself the authority to manage and discipline its clergy it is not likely that a court will inquire further, even if the denomination is connectional.

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