Tavitas, J.
Case Summary
Joshua Payne-Elliott appeals from the trial court’s dismissal, with prejudice, of his complaint for damages against the Roman Catholic Archdiocese of Indianapolis, Inc. (the “Archdiocese”). The trial court dismissed Payne-Elliott’s complaint, stemming from an employment dispute, for lack of subject matter jurisdiction, pursuant to Indiana Trial Rule 12(B)(1), and for failure to state a claim upon which relief can be granted, pursuant to Indiana Trial Rule 12(B)(6).
The State of Indiana and constitutional scholars have tendered briefs, as amici curiae, in support of the Archdiocese; and Lambda Legal Defense & Education Fund, Inc., has proffered an amicus brief in support of Payne-Elliott. [Footnote omitted.]
Without reaching the merits of Payne-Elliott’s claims and the Archdiocese’s various affirmative defenses, we find that the trial court committed reversible error in: (1) summarily dismissing Payne-Elliott’s complaint for lack of subject matter jurisdiction pursuant to Indiana Trial Rule 12(B)(1); (2) failing to treat the Archdiocese’s motion to dismiss for failure to state a claim upon which relief can be granted, pursuant to Trial Rule 12(B)(6), as a motion for summary judgment; and (3) dismissing Payne-Elliott’s complaint with prejudice. For these reasons, we reverse and remand for further proceedings.
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Payne-Elliott maintains that the trial court erred in dismissing his case for lack of subject matter jurisdiction, pursuant to Indiana Trial Rule 12(B)(1). [Footnote omitted.]…
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Payne-Elliott maintains that the trial court erred in dismissing his case for lack of subject matter jurisdiction because “[his] claims do not implicate internal church governance, require the courts to resolve an ecclesiastical controversy, or otherwise excessively entangle the courts with religion.” Payne-Elliott’s Br. p. 18. The Archdiocese counters that, in issuing the directive to Cathedral, it “act[ed] in accordance with ecclesiastical directive[,]” deriving from canon law, which courts cannot review or question. Archdiocese’s Br. pp. 18, 24….
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In its brief in support of Payne-Elliott, amicus curiae Lambda Legal Defense & Education Fund argues as follows:
‘The appropriate procedure for seeking dismissal of a suit by asserting a Free Exercise Clause defense’ is for the court to determine if it is a case where ‘the Free Exercise Clause may under certain facts entitle a party to summary judgment.” West v. Wadlington (emphasis in original, quoting Brazauskas v. Fort Wayne-South Bend Diocese, Inc., 796 N.E.2d 286, 290 (Ind. 2003)). These cases reflect the longstanding approach of rejecting religious employers’ premature cries of complete immunity under the First Amendment.
Lambda Legal’s Br. p. 14; see id. at 15 (“Indeed, without discovery and the ability to develop the factual record, it cannot be known whether the ministerial exception applies to Payne-Elliott’s work as a teacher of world language and social studies to high school students”; “[a]lthough it is possible that the [ecclesiastical abstention] doctrine eventually may prevent recovery by the plaintiff, that is by no means apparent at this juncture and does not support dismissal of Payne-Elliott’s complaint. Jurisdiction should continue unless it is apparent that this dispute cannot be resolved under ‘neutral principles of law.’”).
We agree that the instant matter differs from Brazauskas, in which the issues were already ripe for resolution on summary judgment. As this Court has previously opined:
Generally, the church autonomy doctrine deals with a church’s First Amendment right to autonomy in making decisions regarding its own internal affairs including matters of faith, doctrine, and internal governance. Brazauskas II,[5 ] 796 N.E.2d at 293 (citing Bryce v. Episcopal Church in the Diocese of Colorado, 289 F.3d 648, 655 (10th Cir. 2002)). Acknowledging this doctrine’s limitations, however, the Brazauskas II court observed, “‘The First Amendment does not immunize every legal claim against a religious institution and its members. The analysis in each case is fact-sensitive and claim specific, requiring an assessment of every issue raised in terms of doctrinal and administrative intrusion and entanglement.’” Id. at 293-94 (quoting McKelvey v. Pierce, 173 N.J. 26, 800 A.2d 840, 844 (2002)).
Indiana Area Found. of United Methodist Church, Inc. v. Snyder, 953 N.E.2d 1174, 1178 (Ind. Ct. App. 2011) (citing Brazauskas, 796 N.E.2d at 293).
Here, the parties have yet to undertake the requisite “fact-sensitive and claim specific” analysis that must precede analysis of whether the First Amendment bars Payne-Elliott’s claims against the Archdiocese. For instance, do genuine issues of material fact exist regarding: (1) whether Payne-Elliott’s job duties as a teacher at an Archdiocese-affiliated school rendered him a “minister”; or (2) the applicability of the ecclesiastical abstention doctrine? [Footnote omitted.] At this juncture, discovery in this matter is ongoing, and we find that this matter is well shy of being ripe for summary disposition.
We can, nonetheless, conclusively find the trial court was cloaked with general authority to hear matters involving employment contracts and disputes and erred in concluding otherwise. See Brazauskas, 796 N.E.2d at 290 (“A court with general authority to hear matters like employment disputes is not ousted of subject matter or personal jurisdiction because the defendant pleads a religious defense.”). Because Payne-Elliott’s employee dispute claims fall “within the general scope of the authority conferred upon [the trial] court by the constitution or by statute[,]” we are compelled to find that the trial court erred in finding that it lacked subject matter jurisdiction to hear such claims. See Reinhart, 112 N.E.3d at 711-12. Accordingly, we find the trial court erred in dismissing the complaint pursuant to Indiana Trial Rule 12(B)(1).
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Conclusion
The trial court erred in granting the Archdiocese’s motion to dismiss for lack of subject matter jurisdiction and for failure to state a claim upon which relief can be granted, pursuant to Indiana Trial Rules 12(B)(1) and 12(B)(6), respectively. The trial court also erred in dismissing Payne-Elliott’s claims with prejudice. We reverse and remand for further proceedings.
Reversed and remanded.
Mathias, J., and Weissman, J., concur.