Presbyterian Church U.S.A. v. Brian Edwards, Judge, Jefferson Circuit Court, et al.

Rev. Hoey, an ordained Presbyterian minister, was called by the denomination to be its Director of Evangelism and Church Growth. During his ministry, Rev. Hoey was involved in the improper redirection of substantial Church funds to a separate religious organization. Church leaders determined that his misconduct violated the Church’s ecclesiastical ethics doctrine, which required him to exercise the “highest degree of stewardship” regarding all Church resources which are “entrusted to the [Church] by God.” He sued the Church for defamation in the Kentucky courts for stating to the Presbyterian community, as required by its Constitution, that he had committed “ethical violations.” All three levels of Kentucky’s judiciary refused, under procedures common in many states, to dismiss Rev. Hoey’s case under the First Amendment’s ecclesiastical abstention or church autonomy doctrine. Thus, the question presented is: Whether, under the Supremacy Clause, the First Amendment requires state courts, despite their own procedures, to dismiss suits immediately upon a showing that the claim turns upon the interpretation or application of religious doctrine or discipline?