Singleton v. Christ the Servant Evangelical Lutheran Church

541 N.W.2d 606, 1996 Minn. App. LEXIS 17, 1996 WL 5669
CourtCourt of Appeals of Minnesota
DecidedJanuary 9, 1996
DocketC9-95-1278
StatusPublished
Cited by15 cases

This text of 541 N.W.2d 606 (Singleton v. Christ the Servant Evangelical Lutheran Church) 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
Singleton v. Christ the Servant Evangelical Lutheran Church, 541 N.W.2d 606, 1996 Minn. App. LEXIS 17, 1996 WL 5669 (Mich. Ct. App. 1996).

Opinion

OPINION

WILLIS, Judge.

Pastor R. Ray Singleton challenges summary judgment in favor of Church and Synod, arguing that the Establishment Clause of the United States Constitution does not bar his claims of breach of contract, promissory estoppel, wrongful discharge, breach of implied covenant of good faith and fair dealing, intentional infliction of emotional distress, and tortious interference with contract. Singleton also argues that the district court erred in granting summary judgment on his claims of defamation. We affirm.

FACTS

Christ the Servant Evangelical Lutheran Church (Church) called Ray Singleton to be its pastor. The letter of call described certain elements of the relationship between the Church and Singleton, including the terms of a compensation package, which was subject to annual review. Financial problems and conflicts between Church members and their previous pastor regarding theological and administrative matters existed at the Church before Singleton’s arrival and continued throughout his tenure as pastor. Several families left the Church because of differences with Singleton.

Conflicts within the Church heightened in late 1993. In October 1993, the Church council asked Singleton to leave a council meeting and to respond to a list of concerns. The Church formed a task force to consider remedies for the Church’s financial difficulties. At the task force meetings, Church members identified general and specific aspects of Singleton’s job performance as reasons certain members had left the Church and others had quit contributing financially to the Church.

*610 Singleton communicated to the St. Paul Area Synod of the Evangelical Lutheran Church (Synod) that he wanted to pursue another call and in late December 1993 he interviewed with five other synods. The Synod communicated frequently with Singleton and with Church members throughout this period regarding Singleton’s employment and problems at the Church.

On December 21, 1993, the Church council recommended a budget for 1994 that reduced Singleton’s annual salary by $16,000. The Church council president drafted a report that included a request for Singleton’s resignation. Singleton claims that he was physically and emotionally unable to continue his duties as pastor after receiving the council president’s report on January 10, 1994 and that he was unable emotionally to formulate a response to the demand for his resignation. Approximately two weeks later, the congregation adopted a budget for 1994 that reduced the amount available for pastoral services to $3,368.

Singleton sued the Church, asserting claims of breach of contract, wrongful discharge, promissory estoppel, breach of the implied covenant of good faith and fair dealing, defamation, intentional infliction of emotional distress, and negligent infliction of emotional distress. In addition, Singleton brought claims against the Synod for tortious interference with contract, breach of the implied covenant of good faith and fair dealing, and defamation. The district court entered summary judgment in favor of the Church and the Synod on all claims. Singleton appeals. 1

ISSUES

1. Did the district court err in determining that the Establishment Clause warranted summary judgment on Singleton’s claims of breach of contract, wrongful discharge, promissory estoppel, breach of the implied covenant of good faith and fair dealing, and tortious interference with contract?

2. Did the district court err in granting summary judgment in favor of the Church and Synod on Singleton’s defamation claims?

ANALYSIS

On appeal from summary judgment, this court asks whether any genuine issues of material fact exist and whether the district court erred in its application of the law. State by Cooper v. French, 460 N.W.2d 2, 4 (Minn.1990). A reviewing court is not bound by and need not give deference to a district court’s decision on a purely legal issue. Frost-Benco Elec. Ass’n v. Minnesota Pub. Utils. Comm’n, 358 N.W.2d 639, 642 (Minn.1984).

I.

The Church and the Synod allege that the First Amendment to the United States Constitution prevents civil courts from reviewing Singleton’s claims. The Establishment Clause of the First Amendment provides that “Congress shall make no law respecting an establishment of religion ⅜ * U.S. Const, amend. I. The First Amendment applies to the states through the Fourteenth Amendment. Cantwell v. Connecticut, 310 U.S. 296, 303, 60 S.Ct. 900, 903, 84 L.Ed. 1213 (1940). Under the Establishment Clause, an exercise of governmental authority is valid if it (1) has a secular purpose, (2) neither inhibits nor advances religion as its primary effect, and (3) does not create excessive entanglement between church and state. Lemon v. Kurtzman, 403 U.S. 602, 612-13, 91 S.Ct. 2105, 2111, 29 L.Ed.2d 745 (1971).

Whether government action causes excessive entanglement depends on the nature of the intrusion into religious administration, the character and purpose of the involved institutions, and the resulting relationship between the religious authority and government. Lemon, 403 U.S. at 615, 91 S.Ct. at 2112; Black v. Snyder, 471 N.W.2d 715, 720 (Minn.App.1991), review denied (Minn. Aug. 29, 1991). If a claim involves core issues of ecclesiastical concern, the potential for excessive governmental entanglement precludes judicial review. Serbian E. *611 Orthodox Diocese v. Milivojevich, 426 U.S. 696, 721-23, 96 S.Ct. 2372, 2386-87, 49 L.Ed.2d 151 (1976) (holding that the First Amendment barred judicial consideration of bishop’s wrongful discharge claim). If the court can resolve the dispute by looking only to neutral principles of law, however, judicial review is permissible. Jones v. Wolf, 443 U.S. 595, 602-05, 99 S.Ct. 3020, 3025-26, 61 L.Ed.2d 775 (1979) (applying neutral principles of law analysis to church property dispute); Piletich v. Deretich, 328 N.W.2d 696, 701 (Minn.1982) (adopting neutral principles of law analysis for “resolution of church property and membership disputes”).

A. Claims of Breach of Contract, Wrongful Discharge, and Promissory Estoppel Against the Church

Singleton claims that the Church breached its contract with him and wrongfully discharged him by violating provisions of the Church’s constitution and the terms of his call.

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Bluebook (online)
541 N.W.2d 606, 1996 Minn. App. LEXIS 17, 1996 WL 5669, Counsel Stack Legal Research, https://law.counselstack.com/opinion/singleton-v-christ-the-servant-evangelical-lutheran-church-minnctapp-1996.