Rashedi v. Gen. Bd. of Church of the Nazarene
In Rashedi v. Gen. Bd. of Church of the Nazarene, 203 Ariz. 320, 323, P 14, 54 P.3d 349, 352 (App. 2002), the plaintiff alleged that the priest "engaged in sexual relations with her by using his position as pastor and spiritual advisor to exert emotional and physical control over her in an attempt to defraud her of money." 203 Ariz. at 322, P 4, 54 P.3d at 351.
The Court framed the issue to be "whether the civil court can adjudicate claims against certain officials of a religious organization based on their alleged licensing and hiring of a pastor whom they knew or had reason to know was likely to victimize members of that organization." Id. at 324, P 17, 54 P.3d at 353.
The Court noted that "the parties here have not specifically addressed individual claims at this stage of the litigation." Id. at 326, P 27, 54 P.3d at 355.
The Court stated that "because the parties presented a general challenge to the court's jurisdiction to consider the case, we have addressed the matter generally." Id.
Thus, while we determined that neutral principles of law could apply to the dispute in Rashedi, in which a parishioner was sexually victimized by a priest, we did not indicate whether the ecclesiastical abstention doctrine would apply to some or all of the individual claims.
And, importantly, we specifically noted that the First Amendment precluded civil courts from "inquiring into internal organizational disputes between different factions." Id. at 323, P 14, 54 P.3d at 352.