John Doe v. The First Presbyterian Church U.S.A. of Tulsa, Oklahoma and James D. Miller

Summary

The Oklahoma Supreme Court held that the church autonomy doctrine did not deprive the district court of subject matter jurisdiction over John Doe's tort and contract claims arising from publication of his baptism on the internet. Because the district court relied on disputed facts central to the claims, its jurisdictional dismissal should have been treated as a motion for summary judgment, and summary adjudication was premature. The court reversed and remanded, emphasizing that the church autonomy doctrine operates as an affirmative defense and that Doe was not alleged to have become a church member.

Holdings

1. When evidence outside the pleadings submitted on a subject-matter-jurisdiction motion concerns disputed facts that are also elements of the plaintiff's claims, the motion must be treated as a motion for summary judgment. Because the district court resolved disputed factual issues central to Doe's claims, dismissal for lack of subject matter jurisdiction was erroneous.
2. The church autonomy doctrine did not deprive the Oklahoma district court of subject matter jurisdiction over Doe's claims. The doctrine, as applied under the majority's analysis, operates as an affirmative defense rather than a jurisdictional bar.
3. Because Doe undisputedly did not become a church member and the record contained no evidence that he consented to the church's broader ecclesiastical jurisdiction, the church could not rely on ecclesiastical jurisdiction to eliminate the court's authority to hear his claims.

Questions Presented

1. Whether a motion to dismiss for lack of subject matter jurisdiction must be treated as a motion for summary judgment when the court considers disputed evidence relating to facts central to the plaintiff's claims.
2. Whether the church autonomy doctrine deprived the Oklahoma district court of subject matter jurisdiction over Doe's tort and breach-of-contract claims.
3. Whether the church autonomy doctrine applied where Doe received baptism but undisputedly did not become a member of the church or consent to its broader ecclesiastical governance.

Disposition

reversed_and_remanded