
U.S. Fifth Circuit Court of Appeals.
OXFORD, Miss. (BP) — The Fifth Circuit Court of Appeals has upheld a previous dismissal in favor of the North American Mission Board (NAMB) regarding a years-long case brought by former Maryland/Delaware state executive Will McRaney.
“On the merits, the church autonomy doctrine bars all of McRaney’s claims against NAMB,” read the presiding opinion. “Although his claims are facially secular, their resolution would require secular courts to opine on ‘matters of faith and doctrine’ and intrude on NAMB’s ‘internal management decisions that are essential to (its) central mission.’ That we cannot do.”
The decision further ordered McRaney to pay NAMB’s court costs for the appeal, as determined by the court clerk.
Judge Irma Carrillo Ramirez dissented, agreeing with McRaney’s claim that the ecclesiastical abstention doctrine did not apply to the case.
Historical cases that established the doctrine occurred through religious groups that included higher “ecclesiastical tribunals,” she said. And “unlike the hierarchical churches (in those cases), there is no unified ‘Baptist Church.’”
The court’s decision solidifies religious freedom, NAMB said in a statement.
“We are pleased with yesterday’s decision from the Fifth Circuit Court of Appeals,” it said. “The Court rejected all assertions that Baptists and other non-hierarchical faith groups do not enjoy the same religious freedoms as other faith groups. Indeed, this decision constitutes a landmark decision that protects Baptist religious liberty.
“To be clear, nothing in the Fifth Circuit Court’s decision diminishes church autonomy, voluntary cooperation, or any other Baptist doctrinal distinctive. On the contrary, the ruling expressly upholds the freedom of every Baptist church and ministry to practice these doctrines free from government interference. The decision was grounded in these Constitutional rights.”
In a statement to Baptist Press, NAMB lead attorney Matthew T. Martens called the decision “a landmark victory for religious liberty for Baptists.
“It ensures that First Amendment doctrines that have been applied to hierarchical denominations apply with equal force to Baptists, who operate not by hierarchy but through voluntary associations. It is, of course, fitting that Baptists, who championed religious liberty at the nation’s founding, should likewise be entitled to it.”
Baptist Press reached out to McRaney’s attorney for comment but did not receive a response by press time.
“Rather than continuing to ask the government to step in where the Constitution forbids it and rather than seeking to overturn this momentous win for Baptists and religious liberty throughout the nation, our hope is that the plaintiff will choose to cease his pursuit of this matter through the courts and focus on more positive activities through the church he pastors and his other ministry endeavors. We will pray all the best for him in those efforts,” NAMB said.
McRaney’s lawsuit, originally filed in 2017, claims that NAMB’s interference and influence led to his 2015 termination as state executive for the Baptist Convention of Maryland/Delaware (BCMD). The suit was dismissed in April 2019 due to the ecclesiastical abstention doctrine, but that decision was later overruled and remanded back to a district court on appeal.
NAMB filed an appeal in February 2021 with the U.S. Supreme Court, which declined to hear the case. In August 2023, a federal judge dismissed the case again, to which McRaney appealed again. Attorneys for the two sides faced off before the three-judge panel of the Fifth Circuit Court of Appeals in April 2024.
“NAMB has endured protracted discovery, two rounds of summary judgment, a previous appeal, and a close en banc rehearing poll,” wrote the appeals court majority while citing previous cases on the subject. “Regrettably, this litigation has caused NAMB’s and BCMD’s ‘(c)hurch personnel and records’ to ‘become subject to … the full panoply of legal process designed to probe the mind of the church in the selection of its ministers.’ This unconstitutional violation of church autonomy ends today.”
(EDITOR’S NOTE — Scott Barkley is chief national correspondent for Baptist Press.)