Foundation for the Advancement of Catholic Schools, Inc. v. Blair

Citations

• 230 Conn. App. 793

Syllabus

The plaintiffs, a corporation and five members of its board of trustees, appealed from the trial court's judgment dismissing, for lack of subject matter jurisdiction, their declaratory judgment action that sought, inter alia, an interpretation of the corporation's bylaws governing the appointment of trustees to its board. The plaintiffs, who had commenced the action after certain appointments to the board were made by the named defendant, the former archbishop of the diocese of Hartford, claimed that the court erred in determining that exercising jurisdiction over the action would have vio- lated the free exercise and establishment clauses of the first amendment to the United States constitution because adjudicating the dispute would have resulted in the excessive entanglement of government and religion. Held: The trial court improperly granted the defendants' motion to dismiss for lack of subject matter jurisdiction on the basis of its determination that the plaintiffs' action asked the court to entangle itself in matters of religious doctrine and practice and church polity, as there was no first amendment barrier prohibiting the court from applying neutral principles of state law governing corporations to the secular language of the corporation's bylaws for the purpose of declaring the process to be followed in appointing board members and determining the validity of certain appointments to the board. This court declined to adjudicate the defendants' alternative grounds for affirming the judgment, specifically, that the plaintiffs' lacked standing to bring the action, because doing so would have required a resolution of disputed jurisdictional facts, which require an evidentiary hearing, and, thus, the case was remanded to the trial court for consideration of those standing claims and a hearing thereon. Argued October 7, 2024—officially released February 25, 2025