Winkler v. Marist Fathers of Detroit, Inc.
Docket No. 152889
Trial Lawyers’ Bottom Line: Ecclesiastical abstention doctrine is never relevant to a court’s subject matter jurisdiction.
The Marist Fathers of Detroit operate two private, Catholic schools, Notre Dame Prep and Marist Academy, in Oakland County. Bettina Winkler attended the middle school for these two institutions, but was denied admission to the high school. She believed the school rejected her because she had dyslexia, a learning disability. She sued under MCL 37.1402, part of the Persons with Disabilities Civil Rights Act.
The Marist Fathers of Detroit moved for summary disposition, arguing that the ecclesiastical abstention doctrine deprived the circuit of subject matter jurisdiction over a challenge to admissions decisions of a religious school. The Marist Fathers also argued that the Persons with Disabilities Civil Rights Act did not apply to religious institutions. The circuit court denied the motion on both grounds. The Court of Appeals reversed, relying on Dlaikan v. Roodbeen, 206 Mich App 591 (1994). The panel said that, under the First Amendment, civil courts cannot analyze the decisionmaking process of a religious institution regarding admission. As a result, the panel did not need to reach the question of whether the Act applies to religious schools. The Supreme Court granted leave to appeal.
The Court first clarified that there is no dispute that circuit courts possess subject matter jurisdiction over claims of discrimination under the Act. Further, the ecclesiastical abstention doctrine informs how civil courts must adjudicate claims involving ecclesiastical questions. The doctrine does not deprive courts of subject matter jurisdiction over those claims. In a footnote, the Court listed a number of cases that had erroneously described the ecclesiastical doctrine as affecting a civil court’s “jurisdiction.”
Then the opinion fleshed out the ecclesiastical abstention doctrine, which arises from the First Amendment. The Court said the idea behind the doctrine is that a court cannot substitute its opinion “in lieu of the authorized tribunals of the church in ecclesiastical matters.” The Court clarified that the doctrine does not “purport to deprive civil courts of the right to exercise judicial power over any given class of cases.”
The Court then added that affixing the label of subject matter jurisdiction to the ecclesiastical abstention doctrine by the Dlaikan court was an error. Subject matter jurisdiction is about categories of cases; the ecclesiastical abstention doctrine is about the particular facts of the case before the court. The Court summarized that what matters instead is whether the actual adjudication of a legal claim requires resolution of ecclesiastical questions. If so, the doctrine requires a court to defer to the religious entity’s resolution of those questions.
Next, the Court moved to whether the doctrine defeated Winkler’s claim. Prior ecclesiastical doctrine cases required the Court to defer to a church’s expulsion of pastors and members. The Marist Fathers of Detroit said this case was no different. The Court decided not to reach this issue, however, because the lower courts had not adjudicated it yet. Thus, the Court reversed the lower-court decision and remanded the case to the Court of Appeals to determine this issue—which that court had refused to reach based on its determination that the court lacked jurisdiction.
Full opinion here.