## Facts

- Saint Meinrad School of Theology is a Catholic seminary that trains candidates for priesthood and other ministries.
- Dr. Carmel McEnroy was employed as a professor of Catholic theology and doctrine under a contract that incorporated the Faculty Constitution, Faculty Handbook, and Statement of Governance.
- The incorporated governance documents provided that the seminary operates in accordance with Roman Catholic canon law and placed final jurisdiction over the seminary in the Archabbot.
- In 1994, Pope John Paul II issued an Apostolic Letter stating that the question of women’s ordination was resolved and not open to debate.
- Dr. McEnroy signed a published open letter opposing the pope’s teaching on women’s ordination.
- The Archabbot concluded that Dr. McEnroy was seriously deficient in her duties by publicly dissenting from papal teaching and that canon law required her removal from the faculty.
- The Archabbot directed the seminary’s President–Rector to remove Dr. McEnroy, and she was removed from the faculty.
- Dr. McEnroy sued the seminary and church officials for breach of contract, tortious interference with contractual relations, and breach of an implied covenant of good faith and fair dealing.

## Issues

1. Whether civil courts have subject-matter jurisdiction over Dr. McEnroy’s contract-based claims, or whether adjudicating them would require religious determinations barred by the First Amendment.

## Decision

- The Indiana Court of Appeals affirmed the trial court’s dismissal for lack of subject-matter jurisdiction under Indiana Trial Rule 12(B)(1).
- The court held that deciding the claims would require interpreting and applying religious doctrine and canon law concerning ecclesiastical governance and discipline.
- Because adjudication would excessively entangle the court in matters of church faith, discipline, and internal organization, the First Amendment prohibited judicial resolution of the dispute.

## Legal Principles

- Civil courts may not decide questions of church discipline, faith, internal organization, or ecclesiastical rule, custom, or law.
- Courts may apply “neutral principles” to disputes involving religious entities only when resolution does not require deciding religious doctrine or polity.
- When employment terms expressly incorporate ecclesiastical governance and canon law, contract and related tort claims may be nonjusticiable if resolution turns on religious judgments.
- First Amendment church-autonomy limits can deprive a court of subject-matter jurisdiction when the claims cannot be adjudicated without religious interpretation.

## Conclusion

The court dismissed the professor’s contract and related claims because resolving whether her removal was wrongful would require a civil court to interpret canon law and assess ecclesiastical determinations about public dissent and church authority, which the First Amendment forbids.


McEnroy v. Saint Meinrad Sch. of Theology, 713 N.E.2d 334 (Ind. Ct. App. 1999)