Schoenhals v. Mains

504 N.W.2d 233, 1993 Minn. App. LEXIS 780, 1993 WL 286877
CourtCourt of Appeals of Minnesota
DecidedAugust 3, 1993
DocketC1-93-329
StatusPublished
Cited by20 cases

This text of 504 N.W.2d 233 (Schoenhals v. Mains) is published on Counsel Stack Legal Research, covering Court of Appeals of Minnesota primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Schoenhals v. Mains, 504 N.W.2d 233, 1993 Minn. App. LEXIS 780, 1993 WL 286877 (Mich. Ct. App. 1993).

Opinion

OPINION

FORSBERG, Judge.

Following their expulsion as members of Faith Tabernacle of Truth Church (Church), Larry and Nancy Schoenhals brought this action against the Church and its pastor, Ronald Mains. The district court granted summary judgment to the Church and Mains, and dismissed the Schoenhals’ claims of fraud and defamation.

The Schoenhals appeal. We affirm.

FACTS 1

In mid-July 1988, Mains asked the Scho-enhals to sign a guaranty on behalf of the Church. Mains represented to them that if the Church ever defaulted, the guarantors would split any profits which were made on the sale of the Church.

In August 1988, Larry Schoenhals executed a guaranty to First Western Bank for the payment and performance of certain debts, liabilities, and obligations of the Church. In October 1989, the Schoenhals were notified that the Church had been late in making several payments. 2

The Schoenhals thereafter retained an attorney, and discontinued their contact with the Church. However, they never notified the Church of their intent to terminate their memberships. Indeed, in a November 29, 1989 letter to Mains from the Schoenhals’ attorney requesting their release from the guaranty, the Schoenhals were referred to in the present tense as “founding members and supporters of the church.”

Mains indicated by return letter that he would respond by January 15, 1990. On that date, Mains issued a letter dismissing the Schoenhals from membership in the Church. In this “Letter of Transfer/Termination of Membership,” Mains set out the following reasons for the Schoenhals’ termination of membership:

1. A lack of financial stewardship with consistency and faithful tithing and offering over a given period of time.
2. A desire on your part to consistently create division, animosity and strife in the fellowship.
3. Direct fabrication of lies with the intent to hurt the reputation and the establishment of Faith Tabernacle of Truth Church and congregation.
4. Backbiting, railing accusations, division, lying, are some of 'the most serious sins found in the Bible. Where, by all appearances and related conversations, you have fallen into all of the categories.

*235 The letter was read to the .entire congregation, and Mains discussed the letter with the Schoenhals’ son, who was also a member of the Church.

In February 1990, Mains met with the Church guarantors, including the Schoen-hals. At that meeting, Mains admitted to the Schoenhals that no profits would be split by the guarantors if the Church was ever sold.

The Schoenhals brought this action in October 1990, alleging fraud, defamation, and breach of contract by promissory es-toppel. The Church and Mains moved for summary judgment on all counts. In granting their motion, the district court concluded the fraud claim was insufficient as a matter of law because it was based upon a future contingency or prediction, and the defamation claim required the court to conduct an impermissible inquiry into a church’s religious affairs, which is prohibited by the First Amendment to the United States Constitution. The Schoen-hals appeal the dismissal of their defamation and fraud claims.

ISSUES

1. Did the district court err in granting summary judgment on the Schoenhals’ defamation claim?

2. Did the district court err in granting summary judgment on the Schoenhals’ fraud claim?

ANALYSIS

On review of a grant of summary judgment, this court must determine whether there are any genuine issues of material fact and whether the trial court erred in its application of the law. Wartnick v. Moss & Barnett, 490 N.W.2d 108, 112 (Minn.1992). In so doing, we must view the evidence in a light most favorable to the party against whom summary judgment was granted. Id.

I.

The First Amendment precludes the making of laws “respecting the establishment of religion.” U.S. Const.Amend. 1. This clause requires, among other things, that a law or regulation not foster excessive governmental entanglement with religion. Black v. Snyder, 471 N.W.2d 715, 719-20 (Minn.App.1991), pet. for rev. denied Aug. 29, 1991) (citing Lemon v. Kurtzman, 403 U.S. 602, 612-13, 91 S.Ct. 2105, 2111, 29 L.Ed.2d 745 (1971)). Thus, the First Amendment precludes judicial review of claims involving “ ‘core’ questions of church discipline and internal governance.” Black, 471 N.W.2d at 720 (citing Serbian Eastern Orthodox Diocese v. Milivojevich, 426 U.S. 696, 717, 721, 96 S.Ct. 2372, 2384, 2386, 49 L.Ed.2d 151 (1976)).

Excessive entanglement may occur when judicial review of a claim requires “a searching * * * inquiry into church doctrine.” Milivojevich, 426 U.S. at 723, 96 S.Ct. at 2387. Such a claim might involve a church’s stated reasons for rejecting an individual for pastorship or a church’s stated reasons for failing to appoint an individual as an associate pastor and discharging her. See, e.g., Minker v. Baltimore Annual Conf. of United Methodist Church, 894 F.2d 1354, 1360-61 (D.C.Cir.1990); Black, 471 N.W.2d at 720 (church’s stated reason for individual’s discharge was her “inability to conduct her ministry efficiently”). However, when a claim may be resolved by “ ‘neutral methods of proof’ ” unrelated to issues of church doctrine or governance, then the First Amendment will not prohibit judicial review. See Black, 471 N.W.2d at 720 (quoting Minker, 894 F.2d at 1361).

The Schoenhals’ claim of defamation centers upon Mains’ statements supporting the decision to terminate the Schoenhals’ membership in the Church. The Church and Mains assert the basis for the statements are in the Bible, and in the Church’s religious beliefs and practices as expressed in the Church’s written Articles of Faith and By-laws. 3

In order to be defamatory, a statement must be communicated to someone other than the plaintiffs, must be false, and *236 must tend to harm the plaintiffs reputation in the community. Stuempges v. Parke, Davis & Co., 297 N.W.2d 252, 255 (Minn.1980). As the district court in this case reasoned:

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Bluebook (online)
504 N.W.2d 233, 1993 Minn. App. LEXIS 780, 1993 WL 286877, Counsel Stack Legal Research, https://law.counselstack.com/opinion/schoenhals-v-mains-minnctapp-1993.