Bibiji Inderjit Kaur Puri, et al. v. Sopurkh Kaur Khalsa, et al.

Petitioners, the widow and three adult children of Siri Singh Sahib Harbhajan Singh Khalsa Yogiji, aka Yogi Bhajan, brought this lawsuit to require two corporations established and exclusively controlled by Yogi Bhajan to comply with their Articles and Operating Agreements and appoint Petitioners to their Boards, as is required by Oregon Corporate Laws. Yogi Bhajan’s trusted assistants who served on the Boards of the two entities when he died did not implement his plan of succession so that they could convert assets from those entities, and improperly withheld documents and information from Petitioners. The District Court ruled on summary judgment that Petitioners’ claims were barred under the First Amendment by the Ministerial Exception and Ecclesiastical Abstention doctrine and did not rule on any other issue. The Ninth Circuit Court of Appeals, on de novo review, eschewed the First Amendment issues and instead ruled Petitioners’ claims were time-barred under the statute of limitations, weighing the evidence on disputed facts and making findings of fact at odds with the underlying evidence. 1. May a Court of Appeals on de novo review of summary judgment refuse to decide a claim predicated on a failure of two non-religious corporations, with religious affiliates, to comply with neutral principles of corporate law, when the sole basis for the District Court’s decision was that the Ministerial Exception and Ecclesiastical Abstention Doctrine barred the claim?