The Indiana Supreme Court has ruled for the Roman Catholic Archdiocese of Indianapolis, finding the church-autonomy doctrine prohibits the state from interfering in the Catholic Church’s dispute with a high school teacher who claimed he was fired for being in a same-sex marriage.
A four-member Supreme Court affirmed the dismissal of Payne-Elliott’s lawsuit under Indiana Trial Rule 12(B)(6) for failure to state a claim upon which relief can be granted. Justice Geoffrey Slaughter wrote the eight-page opinion published Wednesday with Justice Mark Massa concurring and Justices Steven David and Christopher Goff concurring in judgment.
None of the concurring justices wrote separately. Chief Justice Loretta Rush did not participate.
“Religious freedom protected by the First Amendment to the United States Constitution encompasses the right of religious institutions ‘to decide for themselves, free from state interference, matters of church government as well as those of faith and doctrine,’” Slaughter wrote in Joshua Payne-Elliott v. Roman Catholic Archdiocese of Indianapolis Inc., 22S-CP-302. “… This principle, known as the church-autonomy doctrine … applies in this case and requires its dismissal under Indiana Trial Rule 12(B)(6).”
Payne-Elliott sued the Roman Catholic Archdiocese of Indianapolis in July 2019 after his teaching contract with Cathedral High School was terminated. He alleged the Archdiocese discriminated against him because he is gay and married to a man.
The complaint in Joshua Payne-Elliott v. Roman Catholic Archdiocese of Indianapolis Inc., 49D01-1907-PL-027728, claimed the church leadership intentionally interfered with the teacher’s contractual relationship and employment.
After the first special judge assigned to the case recused himself, Judge Lance Hamner issued a one-page ruling dismissing Payne-Elliott’s lawsuit. The Court of Appeals of Indiana reversed in November 2021, which led to the Archdiocese seeking transfer to the Supreme Court.
Before the Supreme Court, the Archdiocese had asserted three grounds for dismissal—church autonomy, freedom of expressive association and the ministerial exception. However, in the opinion, the justices just addressed the church-autonomy defense because Payne-Elliott pleaded all the elements of the doctrine.
The justices also focused on the doctrine during oral arguments on June 28.
Pointing to Brazauskas v. Fort Wayne-South Bend Diocese, Inc., 796 N.E.2d 286, 293 (Ind. 2003), the Supreme Court maintained the church-autonomy doctrine does not give carte blanche to the Catholic Church.
“Brazauskas also explained that the ‘First Amendment does not immunize very legal claim against a religious institution and its members’, and that the analysis in each case ‘is fact-sensitive and claim specific, requiring an assessment of every issue raised in terms of doctrinal and administrative intrusion and entanglement,’” Slaughter wrote. “In other words, the church-autonomy doctrine does not provide an automatic per se defense simply because a religious organization invokes it.”
Yet, in using Brazauskas as a guide, the Supreme Court found that Payne-Elliott’s civil lawsuit established the church-autonomy defense and, therefore, required dismissal.
Namely, the teacher’s complaint alleged the tort claim of the Archdiocese interfering with an employment contract and it rested on the Archdiocese directing Cathedral to fire Payne-Elliott or forfeit its Catholic status. The Supreme Court concluded that the Archdiocese’s communication with the high school was a matter regarding internal church policy, which did not culminate in a criminal act.
“Thus, Payne-Elliott’s complaint establishes the church-autonomy defense,” Slaughter wrote, “and requires dismissal for much the same reason Brazauskas lost.”