State Intervention In Internal Church Disputes In Arizona

In Arizona, "if the subject matter of an internal church dispute is not appropriate for state intervention, then abstention is equally compulsory whether the church is congregational or hierarchical, and whether the dispute has been addressed by an adjudicatory body, if any, within the church." Id. at 1111. The Court was persuaded that a contrary interpretation violates the religion clauses of the First Amendment. Not protecting congregational churches would require civil courts to make legal conclusions regarding interpretation and application of ecclesiastical matters, which the First Amendment forbids. See: Esformes v. Brinn, 52 A.D.3d 459, 860 N.Y.S.2d 547, 547 (N.Y. App. Div. 2008) (holding resolution of dispute between members, board of directors, and board of trustees of church regarding termination of rabbi's contract violates the establishment clause); Turner v. Church of Jesus Christ of Latter-Day Saints, 18 S.W.3d 877, 892-93 (Tex. App. 2000) (finding the establishment clause prohibits civil courts from determining whether church's missionary training program adequately prepares missionaries for life abroad); Roman Catholic Diocese of Jackson v. Morrison, 905 So.2d 1213, 1229-30 (Miss. 2005) (holding the establishment clause does not prohibit claims against a Catholic Diocese for priest's sexual abuse of children because the claims do not entangle the court in church doctrine and belief).