Beverly M. Brazauskas v. Fort Wayne-South Bend Diocese, Inc., Sacred Heart Parish, and Jose Martelli

Summary

The Indiana Supreme Court held that the trial court had subject-matter jurisdiction over claims for blacklisting and tortious interference despite the defendants' First Amendment Free Exercise defense. The court concluded that the church autonomy doctrine protected communications and coordination among Catholic church officials concerning the plaintiff's prospective employment, and it directed entry of summary judgment for the defendants. Justice Sullivan concurred in part and dissented in part.

Holdings

1. A court with general authority to hear employment disputes is not deprived of subject-matter or personal jurisdiction merely because a defendant asserts a religious defense. The defense may instead entitle the defendant to summary judgment under the applicable procedural rules.
2. Under the facts presented, the Free Exercise Clause entitled the Diocese defendants to summary judgment on Brazauskas's blacklisting claim because applying the blacklisting statute to penalize communication and coordination among church officials concerning internal church policy and administration would violate the church-autonomy doctrine.
3. The tortious-interference claim failed because the alleged conduct was protected for the same Free Exercise and church-autonomy reasons, and Brazauskas had not established the independent illegal conduct required for the tort.

Questions Presented

1. Whether a religious defense under the First Amendment's Free Exercise Clause deprives a state court of subject-matter jurisdiction over employment-related tort claims.
2. Whether the Diocese defendants were entitled to summary judgment on Brazauskas's blacklisting claim under the church-autonomy doctrine and the Free Exercise Clause.
3. Whether Brazauskas's tortious-interference claim could proceed where the alleged conduct involved church officials communicating and coordinating about internal church administration and she had not established independent illegal conduct.

Disposition

reversed_and_remanded