## Facts

- Jae-Woo Cha served as an “educational pastor” for the Korean Presbyterian Church of Washington, an unincorporated religious association governed by a Session/Elders Committee.
- Cha alleged an employment agreement with the church for an indefinite term and satisfactory performance of his duties.
- Cha claimed the church wrongfully terminated his pastoral employment.
- Cha further alleged that certain church leaders tortiously interfered with his employment relationship with the church.
- Cha also alleged that certain leaders defamed him through false statements harming his reputation in connection with his removal.
- The church and individual defendants moved to dismiss, asserting that the federal and state free-exercise protections barred civil-court review of internal church governance and discipline.

## Issues

1. Whether the First Amendment and Va. Const. art. I, § 16 bar civil-court adjudication of a former pastor’s claims for wrongful termination, tortious interference with contract, and defamation when resolution would require inquiry into internal church governance and clergy selection.
2. Whether the claims could be resolved using neutral principles of law without deciding ecclesiastical questions.

## Decision

- The Supreme Court of Virginia affirmed the circuit court’s dismissal for lack of subject matter jurisdiction.
- The court held that adjudicating the claims would require impermissible judicial involvement in ecclesiastical matters, including a church’s decision to retain or remove its pastor.
- The court concluded neutral principles could not be applied because the asserted tort claims were inseparable from internal church governance, discipline, and judgments about pastoral fitness.

## Legal Principles

- Civil courts may not decide ecclesiastical disputes or interfere in matters of church government, faith, or doctrine under the First Amendment and Va. Const. art. I, § 16.
- A church’s selection, retention, and removal of clergy is an ecclesiastical concern generally beyond civil-court authority.
- Neutral principles may resolve some church-related civil disputes, but not when adjudication would require evaluating internal governance or religious judgments tied to clergy status and discipline.
- When tort claims are intertwined with a church’s decision-making about clergy and related internal communications, civil courts lack subject matter jurisdiction.

## Conclusion

Because Cha’s wrongful-termination, tortious-interference, and defamation claims could not be resolved without examining the church’s internal governance and judgments concerning pastoral office, the courts lacked subject matter jurisdiction and the dismissal was affirmed.


Cha v. Korean Presbyterian Church of Wash., 262 Va. 604, 553 S.E.2d 511 (Va. 2001)