Donald Christian, et al. v. The Lutheran Church-Missouri Synod, a Missouri Nonprofit Corporation

Differences over church-controlled governance led a university in Texas to remove itself from the church’s university system. The church’s two highest ecclesiastical bodies rejected the university’s action and decreed that the university and its campus had to re-submit to church control, but the university refused to acquiesce. The church’s nonprofit corporate arm, a Missouri citizen, then filed a diversity suit against the university and its officials, requesting judicial confirmation of the ecclesiastical ruling on state law grounds. The district court dismissed for lack of jurisdiction, finding an absence of the complete diversity required by 28 U.S.C. § 1332(a)(1) because the church, though unnamed as a plaintiff, is the real party to the controversy and, like the university defendants, a Texas citizen. A split Fifth Circuit reversed, finding there was diversity jurisdiction. The court reasoned that judicial deference is owed to the church’s assertion that church doctrine prevents it from being an actual party in the case and said the church autonomy doctrine prevents district courts from using neutral principles to independently determine whether complete diversity exists. The question presented is: Whether the church autonomy doctrine preempts a federal court’s duty to use neutral principles of law to determine diversity jurisdiction.