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Will McRaney v. The North American Mission Board of the Southern Baptist Convention, Incorporated

Paid petition · United States Court of Appeals for the Fifth Circuit, No. 23-60494 · judgment September 9, 2025


Certiorari denied · February 23, 2026
Pre-decision estimate: 5% cert probability

Before the decision, roughly the 4.1% base rate. The model weighted this up for counsel who has won certiorari before and a Fifth Circuit decision below.

Question presented

In the decision below, the Fifth Circuit held that the “church autonomy doctrine” provides a defendant “immunity” from claims by a plaintiff who never worked for the defendant, never served as a minister for the defendant, and never submitted to the authority of the defendant with respect to any ecclesiastical or secular matter. The Question Presented is: Does the church autonomy doctrine apply to, and foreclose, civil law claims which are not disputes about the internal affairs or self-governance of a religious institution?1 1 Petitioner agrees with the Fifth Circuit that the ministerial exception is “one ‘component’ of the church autonomy doctrine” (Pet. App. 14a) and intends that the applicability of the ministerial exception is subsumed within the Question Presented.

Counsel of record

For petitioner
Scott E. Gant
Boies Schiller Flexner LLP

For respondent
Matthew Theodore Martens
WilmerHale

Case

Conference history
Distributed for 1 conference

Amicus briefs
1 cert-stage

Linked docket
25A409

Proceedings

  1. Feb 23 2026
    Petition DENIED.
  2. Feb 09 2026
    Brief amici curiae of Current and Former Baptist Leaders filed. (Distributed)
  3. Jan 14 2026
    DISTRIBUTED for Conference of 2/20/2026.
  4. Jan 09 2026
    Waiver of right of respondent N. Am. Mission Bd., Inc. to respond filed.
  5. Jan 06 2026
    Petition for a writ of certiorari filed. (Response due February 9, 2026)
  6. Oct 09 2025
    Application (25A409) granted by Justice Alito extending the time to file until January 7, 2026.
  7. Oct 08 2025
    Application (25A409) to extend the time to file a petition for a writ of certiorari from December 8, 2025 to January 7, 2026, submitted to Justice Alito.