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Court declines to interfere in former pastor’s breach of contract suit

April 8, 2015

A Greensburg pastor who filed a complaint against his former church after they terminated his contract was not able to prove to the Court of Appeals that the courts could review his claims without reference to either church law or doctrine.

Rev. Steven Matthies signed a contract with The First Presbyterian Church of Greensburg Indiana Inc. in October 2010 as the designated pastor, which gave him salary, housing and five weeks of vacation. But before the three-year term ended, the church terminated the contract for “neglecting his pastoral responsibilities.” 
 
In February 2013, Matthies filed his breach of contract complaint against First Presbyterian, alleging violations of the Wage Claims Statute and Indiana common law. He sought unpaid vacation wages as well as unpaid salary and benefits. First Presbyterian claimed that since he abandoned his pastoral duties, he breached his contract and it did not need to pay him for unused vacation time. 
 
The trial court granted summary judgment in favor of the church because it would be required to resolve the dispute by interpreting and applying religious doctrine or ecclesiastical law, which it could not do based on the First Amendment. 
 
In Steven Matthies v. The First Presbyterian Church of Greensburg Indiana, INC,16A01-1409-PL-380, Matthies argued that the trial court could apply neutral principles of contract law to his claims of breach of contract and failure to pay earned wages/benefits, but the appeals court was not convinced. To address the claims of Matthies’ lawsuit, the court would have to inquire into the religious doctrine of the Presbyterian Church and its polity and determine the duties of the pastor, which is prohibited by the First Amendment, Judge Ezra Friedlander wrote. 
 
Judge Terry Crone wrote separately to say he would affirm summary judgment regarding the breach of contract claim, but reverse it regarding the unpaid vacation wages claim. He believed that claim would not require interpreting or applying religious doctrine or ecclesiastical law.
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