Early Church of God in Christ, Inc. v. Jackson

Citations

• 200 N.E.3d 757
• 2022 Ohio 4034

Syllabus

ECCLESIASTICAL-ABSTENTION DOCTRINE – CONSTITUTIONAL LAW/CIVIL – CHURCH PROPERTY– FIRST AMENDMENT – FIDUCIARY DUTIES – DEMAND FOR ACCOUNTING – DISMISSAL – TRESPASS: The trial court erred in sua sponte dismissing the second and third counts of plaintiff's complaint pursuant to the ecclesiastical abstention doctrine, because the complaint alleged claims for breach of fiduciary duty and an accounting and inspection of records that can be resolved by neutral principles of law. The trial court properly dismissed plaintiff's first count in its complaint for trespass because the issue was ecclesiastical.