Calvary Christian School, Inc. v. Huffstuttler

Tom Glaze, Justice, dissenting. According to the majority, three of the Huffstuttlers’ claims — breach of contract, tortious interference, and outrage relating to Preston’s disenrollment — involve ecclesiastical questions that would require this court to inquire into church doctrine. Consequently, the majority finds that this court lacks jurisdiction to address these claims. I disagree with this conclusion and respectfully dissent.

The facts of this case are simple: Calvary Christian School (CCS) placed a hidden video camera in the ventilation system of a classroom that doubles as a dressing room for high school students. The Huffstuttlers became aware of the camera and, like any reasonable parents, demanded an explanation from the school. At first, CCS denied the camera’s existence; then, CCS’s board of directors — consisting of four members — voted to disenroll Preston Huffstuttler in retaliation for his parent’s continued inquiries.

Here, CCS claims that Preston’s disenrollment was based on the Huffstuttler’s failure to comply with school policies, which according to CCS, are rooted in Matthew 18 principles. Given the factual background of this case, it is clear that CCS’s argument is nothing more than a ploy to avoid liability. The majority fails to see through CCS’s charade, and adopts the argument as its own. In this respect, the majority missed the fundamental difference between an ecclesiastical church and a non-profit school or institution.

The majority relies on the false assumption that CCS is an ecclesiastical institution that falls under the protection of the rule articulated in Watson v. Jones, 80 U.S. (13 Wall.) 679 (1871). “Ecclesiastical” is defined as “[o]f or relating to the church, esp. as an institution.” Black’s Law Dictionary 551 (8th ed. 2004). Moreover, an “ecclesiastical matter” is one that “concerns church doctrine, creed, or form of worship, or the adoption and enforcement, within a religious association, of laws and regulations to govern the membership, including the power to exclude from such an association those deemed unworthy of membership.” Black’s Law Dictionary 551 (8th ed. 2004). Each case cited by the majority involves either a church or a parochial school that is run by a diocese. 1 These cases are distinguishable from the present set of facts because they are truly ecclesiastical institutions; on the contrary, CCS is not.

First, CCS is not affiliated with a religious organization. Second, according to one CCS board member, Terral Neely, the school is open to students of any denomination and there is no requirement that a student or his family be a Christian. Third, CCS does not answer to a religious hierarchy. Instead, CCS is run by a four-member school board which voted to disenroll Preston. Unfortunately for Preston and his parents, their appeal is to the school board, which has an obvious conflict of interest, as it was one of the board’s members, M.C. “Buddy” Lewellen, who was the person responsible for installing the hidden camera used in the unlawful act of spying on young students while they disrobed. Overall, CCS is nothing more than a non-profit organization that must be held responsible for its actions; the majority has erred in holding otherwise.

In finding that this court lacks jurisdiction, the majority has allowed CCS and its four-member board to hide behind a religious cloak; for this reason, I dissent. I also join the dissent handed down by Justice Dickey.

Corbin and Dickey, JJ., join in this dissent. The only school-related case cited by the majority is Gaston v. Diocese of Allentown, 712 A.2d 757 (Pa.1998). In Gaston, Joseph and Susan Gaston brought suit against a parochial school because their children were expelled after the Gastons voiced their objection to a faith based course. Ultimately, the Pennsylvania Supreme Court held that it lacked jurisdiction to hear the case because the reasons for expulsion would necessarily “involve matters of church doctrine.” Unlike the case at bar, the Gaston case involved an ecclesiastical school that was affiliated with, and operated by, a church. Moreover, the issue raised in Gaston clearly involved matters of church doctrine, while the present case does not.