An appeals court panel recently ruled against Will McRaney in his lawsuit accusing a missions agency of defamation.
McRaney, a former Southern Baptist state convention leader, had filed the lawsuit against the Southern Baptist Convention's North American Mission Board (NAMB), claiming that it had gotten him fired from a position with the Baptist Convention of Maryland/Delaware.
A three-judge panel of the United States Court of Appeals for the Fifth Circuit upheld a lower court’s dismissal of McRaney’s case in a 2-1 decision last week.
Circuit Judge Andrew S. Oldham authored the majority opinion, writing that NAMB was protected by “the church autonomy doctrine,” which “prohibits any court from adjudicating McRaney’s claims.”
“Civil courts cannot adjudicate ecclesiastical matters,” Oldham explained. “The church autonomy doctrine also forbids courts from adjudicating matters of church governance, including church discipline and the church’s understanding of its own membership.”
He further stated, “On the merits, the church autonomy doctrine bars all of McRaney’s claims against NAMB. Although his claims are facially secular, their resolution would require secular courts to opine on ‘matters of faith and doctrine’ and intrude on NAMB’s ‘internal management decisions that are essential to [its] central mission.’”
However, Circuit Judge Irma Carrillo Ramirez dissented from the majority, noting that McRaney’s “secular claims against a third-party organization do not implicate matters of church government or of faith and doctrine.”
“Determining whether NAMB acted ‘willfully or wantonly’ does not implicate religious beliefs, procedures, or law,” Ramirez argued.
The dispute stems from a 2012 Strategic Partnership Agreement between NAMB and the Baptist Convention of Maryland/Delaware, aimed at better evangelizing nonbelievers in the region.
At the time, McRaney served as the executive director of the BCMD, but disagreements arose over how to implement the agreement, with NAMB taking issue with his leadership. In June 2015, the BCMD unanimously voted to terminate McRaney, reportedly due to concerns about his leadership abilities.
In 2017, McRaney filed a lawsuit against NAMB, alleging defamation and claiming that the SBC entity had influenced his firing.
A Mississippi judge ruled against McRaney in April 2019, but a three-judge panel of the Fifth Circuit reversed that decision and remanded the case to the lower court for further proceedings.
In February 2021, NAMB filed a petition with the U.S. Supreme Court arguing that it was protected by the ministerial exemption, but the Court declined to hear the case.
