Appellate court protects Baptist association’s autonomy in internal dispute

Washington, D.C. Newsroom, Sep 17, 2025 / 09:00 am

An appellate court in Mississippi dismissed an employment-related lawsuit brought against an agency of the Southern Baptist Convention, ruling that a secular court cannot intervene in matters of religious governance.

The U.S. District Court for the Northern District of Mississippi ruled 2-1 to dismiss Will McRaney’s lawsuit against the North American Mission Board (NAMB), which he first brought over eight years ago. The court cited the long-standing church autonomy doctrine.

McRaney was fired from his role in the Baptist Convention of Maryland/Delaware (BCMD) in 2015 based on a dispute about how to implement the Strategic Partnership Agreement (SPA) between BCMD and NAMB.

According to the court ruling, McRaney was tasked with implementing the SPA’s evangelical objectives to spread the Baptist faith “through church planting and evangelism.” The ruling states the dispute was related to “missionary selection and funding, associational giving, and missionary work requirements.”

The BCMD ultimately voted 37-0 to fire him “because of his wretched leadership,” among other reasons, according to the court. Alternatively, McRaney alleged in his lawsuit that he was fired because NAMB defamed him by spreading “disparaging falsehoods.”

The three-judge panel did not rule on the merits of the dispute, but rather a majority found that resolving the claims would require the court “to decide matters of faith and doctrine,” which the courts do not have the authority to do because religious bodies have autonomy when handling such matters based on Supreme Court precedent related to the First Amendment’s protection of the free exercise of religion.

“The church is constitutionally protected against all judicial intrusion into its ecclesiastical affairs — even brief and momentary ones,” the court ruled.

“Can a secular court determine whether NAMB’s conduct was the ‘proximate cause’ of BCMD’s decision to terminate McRaney, without unlawfully intruding on a religious organization’s internal management decisions?” the judges wrote.

“And can a secular court decide it was ‘false’ that McRaney’s leadership lacked Christlike character?” they continued. “To ask these questions is to answer them: no. The SPA is not a mere civil contract; it is ‘an inherently religious document’ that is ‘steeped in religious doctrine.’”

Hiram Sasser, the executive general counsel for First Liberty Institute, which helped provide legal counsel to NAMB, said in a statement that the court’s ruling is consistent with the First Amendment.

“The First Amendment prohibits the government from interfering with the autonomy of religious organizations and the church,” Sasser said. “No court should be able to tell a church who it must hire to preach their beliefs, teach their faith, or carry out their mission.”

Judge Irma Carrillo Ramirez dissented from the court’s majority, stating: “His secular claims against a third-party organization do not implicate matters of church government or of faith and doctrine.”

McRaney told Baptist News Global that he intends to petition the court for an “en banc” hearing, which would require the entirety of the appellate court to be present for a hearing. He told the outlet that NAMB “fooled the courts” and said the Southern Baptist Convention is “not a church” and he wasn’t employed by NAMB, which means it is not an internal church matter.

In 2023, a Texas judge dismissed a civil lawsuit from a Carmelite monastery against Fort Worth Bishop Michael Olson on similar grounds. The dispute was over a diocesan investigation into an alleged sexual affair between the monastery’s prioress and a priest.

The Carmelite Monastery of the Most Holy Trinity in Arlington, Texas, in this case ultimately entered into a formal association with the Society of St. Pius X, which is not in full communion with the Catholic Church. The bishop called this a “scandalous” act that was “permeated with the odor of schism.” The Holy See suppressed the monastery.