NM Court of Appeals rejects church autonomy defense to claims arising from alleged harassment

I’ve been on vacation the past couple of weeks or so, but in my absence the New Mexico Court of Appeals issued a decision in Galetti v. Reeve that explains the limits of the church autonomy doctrine.

The plaintiff, Melissa Galletti, was a teacher at an elementary school run by the Seventh-Day Adventist church, who alleged that she was fired after complaining that her supervisor, Derral Reeve, had harassed her. Ms. Galetti alleged that her employment contract required the school to inform her of any non-renewal of her contract by May 1, but that the decision to fire her was made after that date, in breach of the contract. She also alleged tort claims against the church, Mr. Reeve, and other individuals who allegedly retaliated against her.

The district court granted the defendants’ Rule 1-012(B)(6) motion to dismiss the complaint, finding that the church autonomy doctrine barred Ms. Galetti’s claims.

In a decision by Judge Garcia, the Court reversed. The Court explained that the church autonomy doctrine, which arises from the First Amendment, prohibits civil courts from reviewing “internal church disputes involving matters of faith, doctrine, church governance, and polity.”

The Court explained that this doctrine did not bar Ms. Galetti’s breach of contract claim, which (as pled) involved only whether the church complied with its obligation to timely inform her of non-renewal, because it could be decided without any “religious intrusion,” and “does not appear to be religious in nature.” The tort claims against the individual defendants were also not barred because “these claims do not concern religious matters.”

The Court was, however, careful to explain that its decision was based on the fact that it was reviewing a motion to dismiss, and that if evidence arose on remand that Ms. Galetti’s claims “cannot be resolved without religious entanglement,” then her claims could still be dismissed at that time.

(UPDATE, June 13, 2014): Professor Leslie C. Griffin of UNLV Law School has written this post about Galetti at a blog called Hamilton and Griffin on Rights. Prof. Griffin agrees with the Court’s opinion, but criticizes it for having “mistakenly accepted the idea that the ‘church autonomy doctrine’ is based on the First Amendment.”

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