Kawimbe v. The African Methodist Episcopal Church

CourtDistrict Court, N.D. Georgia
DecidedAugust 15, 2022
Docket1:20-cv-04711
StatusUnknown

This text of Kawimbe v. The African Methodist Episcopal Church (Kawimbe v. The African Methodist Episcopal Church) is published on Counsel Stack Legal Research, covering District Court, N.D. Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kawimbe v. The African Methodist Episcopal Church, (N.D. Ga. 2022).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF GEORGIA ATLANTA DIVISION

PAUL J.M. KAWIMBE, Plaintiff, v. Civil Action No. THE AFRICAN METHODIST 1:20-cv-04711-SDG EPISCOPAL CHURCH, Defendant.

OPINION AND ORDER This matter is before the Court on Plaintiff Paul J.M. Kawimbe’s motion for reconsideration [ECF 34] of the Court’s Order granting Defendant’s motion to dismiss [ECF 31]. After careful consideration of the parties’ briefing, the Court DENIES the motion. I. Background Kawimbe filed suit against Defendant the African Methodist Episcopal Church,1 seeking indemnification for attorneys’ fees and expenses he incurred in connection with his successful defense in an internal dispute resolution proceeding.2 Following a hearing, the Court granted the Church’s motion to

1 Defendant’s correct name is the African Methodist Episcopal Church, Inc., but the Court denied as moot Kawimbe’s motion to amend, ECF 20, which would have corrected the name, when it dismissed the case. 2 See generally, ECF 1. dismiss, finding that the ecclesiastical abstention doctrine deprived it of jurisdiction.3 Kawimbe moves for reconsideration of the Court’s Order.4 He argues that reconsideration is warranted to correct clear error because, in ruling on the motion

to dismiss, the Court incorrectly found that ecclesiastical abstention is a jurisdictional bar, it improperly ruled on subject matter jurisdiction without giving the parties an opportunity to conduct discovery, and it incorrectly found that it

could not apply neutral principals of law to resolve the case. 5 The Church filed a response in opposition to Kawimbe’s motion,6 and Kawimbe filed a reply.7 II. Legal Standard Under the Local Rules of this Court, “[m]otions for reconsideration shall not

be filed as a matter of routine practice.” LR 7.2(E), NDGa. Rather, such motions should be filed only when “a party believes it is absolutely necessary.” Id. To prove absolute necessity, the moving party must show that there is: “(1) newly discovered evidence; (2) an intervening development or change in controlling law;

3 ECF 31, at 12–13. 4 ECF 34. 5 ECF 34-1, at 6–23. 6 ECF 35. 7 ECF 36. or (3) a need to correct a clear error of law or fact.” Bryan v. Murphy, 246 F. Supp. 2d 1256, 1258–59 (N.D. Ga. 2003). Reconsideration motions cannot be used simply “as an opportunity to show the court how it ‘could have done it better[,]’ . . . present the court with arguments already heard and dismissed[,] or to repackage familiar

arguments to test whether the court will change its mind.” Id. III. Discussion Kawimbe asserts that the Court erred in granting the Church’s motion to dismiss because it (1) incorrectly found that the ecclesiastical abstention doctrine

is a jurisdictional bar;8 (2) improperly granted a factual attack on subject matter jurisdiction before allowing discovery;9 and (3) incorrectly found that it could not apply neutral principles of law to resolve Kawimbe’s claims.10 The Court disagrees

that reconsideration is warranted and addresses each argument in turn. A. The Court Properly Applied the Ecclesiastical Abstention Doctrine as a Jurisdictional Bar. Kawimbe first argues that the Court erred in finding that the ecclesiastical abstention doctrine is a jurisdictional bar as opposed to an affirmative defense.11

8 ECF 34-1, at 6–8. 9 Id. at 8–9. 10 Id. at 9–23. 11 Id. at 6. Kawimbe asserts that the Supreme Court’s decision in Hosanna-Tabor Evangelical Lutheran Church & School v. E.E.O.C., 565 U.S. 171, 195 n.4 (2012), abrogated any prior precedent holding that the ecclesiastical abstention doctrine implicates subject matter jurisdiction. In Hosanna-Tabor, the Supreme Court resolved a circuit

split and found that the ministerial exception to employment discrimination claims is a defense on the merits and not a jurisdictional bar. Id. Kawimbe contends that the ministerial exception, which allows religious institutions sole authority to

select and control its ministers, is an outgrowth of the ecclesiastical abstention doctrine and, accordingly, the ecclesiastical abstention doctrine should similarly be treated as an affirmative defense. As the Church rightly points out,12 however, even after Hosanna-Tabor, the

Eleventh Circuit continues to treat the ecclesiastical abstention doctrine as a jurisdictional concern. Rutland v. Nelson, 857 F. App’x 627, 628 (11th Cir. 2021) (affirming sua sponte dismissal for lack of subject matter jurisdiction based on

ecclesiastical abstention doctrine); Eglise Baptiste Bethanie De Ft. Lauderdale, Inc. v. Seminole Tribe of Fla., 824 F. App’x 680, 683 (11th Cir. 2020), cert. denied, 141 S. Ct. 2622 (2021) (the Eleventh Circuit has “long recognized” that the Establishment and

12 ECF 35, at 5–10. Free Exercise clauses require courts to refrain from adjudicating ecclesiastical disputes); Myhre v. Seventh-Day Adventist Church Reform Movement Am. Union Int’l Missionary Soc’y, 719 F. App’x 926, 928 (11th Cir. 2018) (“Civil courts lack jurisdiction to entertain disputes involving church doctrine and polity.”). The

Court declines to adopt Kawimbe’s broad interpretation of Hosanna-Tabor. Moreover, the sole case cited by Kawimbe, a 2016 decision from the Minnesota Supreme Court, does not support the proposition that the ecclesiastical

abstention doctrine is an affirmative defense. Pfeil v. St. Matthews Evangelical Lutheran Church of Unaltered Augsburg Confession of Worthington, 877 N.W.2d 528, 535 (Minn. 2016). In Pfeil, the Minnesota Supreme Court affirmed dismissal of defamation and tort claims related to statements made by a pastor during an

internal church disciplinary proceeding. Id. at 530. Though the court held that, pursuant to Hosanna-Tabor, the ecclesiastical abstention doctrine was not a jurisdictional bar, it declined to characterize the doctrine as an affirmative defense

instead of a form of abstention, as the name implies, because the parties did not brief or argue the issue and resolution of that issue was not essential. Id. at 535. The court found, nonetheless, that adjudicating the claims would “excessively

entangle the courts with religion and unduly interfere with respondents’ constitutional right to make autonomous decisions regarding the governance of their religious organization,” and that the claims had been properly dismissed. Id. at 542. Even though the characterization of the ecclesiastical abstention doctrine may be up for debate, the Eleventh Circuit has consistently applied it as a

jurisdictional bar. The Court declined to deviate from the Eleventh Circuit’s approach in dismissing Kawimbe’s claims for want of jurisdiction and, more to the point, it was hardly clear error for it to do so. Reconsideration is not warranted.

Kawimbe’s arguments on this issue are better suited for an appeal. B. The Court Found It Lacked Subject Matter Jurisdiction Based on the Face of the Complaint. Kawimbe also argues that reconsideration is necessary because the Court improperly ruled on a factual attack on subject matter jurisdiction without giving him an opportunity for discovery. See Williamson v. Tucker, 645 F.2d 404, 414 (5th

Cir. 1981) (district court must give an opportunity for discovery or a hearing where appropriate for a fact-based 12(b)(1) motion).13 On this point, clarification is necessary.

13 Bonner v. City of Prichard, 661 F.2d 1206, 1207 (11th Cir.

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