U.S. courts have traditionally been reluctant to become involved in internal disputes within a religious organization. These concerns are based on First Amendment prohibitions against interfering with a church’s or other organizations’ operations. Last month, the North Carolina Supreme Court contemplated how to avoid such entanglements in a church dispute that appeared to involve both spiritual and business matters.

In Nation Ford Baptist Church Inc. v. Davis, a terminated pastor claimed that the church did not follow its own bylaws in terms of the steps taken to remove him. The church filed suit against him, seeking an injunction to prevent the pastor from entering the church or interfering with its operations. The pastor countersued, seeking relief based on the alleged improper removal. The church sought dismissal of the counterclaims based on the fact that they involve ecclesiastical matters.

The North Carolina Supreme Court “split the baby,” to use a biblical reference, drawing lines between spiritual and business claims. The pastor’s allegations regarding violation of the church’s bylaws were not religious in nature, and can be adjudicated without entangling the court in religious decisions. However, the court said that it did not have authority to decide the pastor’s tort claims about the basis for the termination, because these questions involve church doctrine.

The court remanded the surviving claims for additional proceedings. While not closing the door to employment claims by church employees, this decision limits the grounds on which such claims can be heard to those that clearly involve contractual or related allegations.

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