Dobrota v. Free Serbian Orthodox Church St. Nicholas
In Dobrota v. Free Serbian Orthodox Church St. Nicholas, 191 Ariz. 120, 952 P.2d 1190 (App. 1998), the Diocesan Ecclesiastical Court determined that a priest's termination of employment with the St. Nicholas Free Serbian Orthodox Church was not conducted in accordance with church rules and ordered the church to pay the priest his salary from the date of his illegal termination and to return the priest's property. 191 Ariz. at 123, P 5, 952 P.2d at 1193.
The priest filed a civil lawsuit when the church refused to pay his salary and return his belongings. Id. at P 6. The Court noted that "a civil court may decide a church and clergy dispute if the methods of resolving it avoid questions of ecclesiastical doctrine or belief." Id. at 126, P 26, 952 P.2d at 1196.
The Court held that "because the Ecclesiastical Court has decided that the Church must pay past compensation and benefits to the priest, the calculation of the amount would not entangle the superior court in any matter of ecclesiastical doctrine or belief." Id.
Thus, neutral principles of law were used to determine the priest's monetary damages. Id.