Supreme Court of Minnesota.
LaVonne PFEIL, Individually and as Trustee for Heirs of Henry Pfeil, deceased, Appellant, v. ST. MATTHEWS EVANGELICAL LUTHERAN CHURCH OF the UNALTERED AUGSBURG CONFESSION OF WORTHINGTON, Nobles County, Minnesota, et al., Respondents.
Decided: April 6, 2016
Zorislav R. Leyderman, The Law Office of Zorislav R. Leyderman, Minneapolis, MN, for appellant. Ken D. Schueler, Jennifer M. Peterson, Dunlap & Seeger, P.A., Rochester, MN; and Timothy J. O’Connor, William L. Davidson, Lind, Jensen, Sullivan & Peterson, P.A., Minneapolis, MN, for respondents. Mark R. Bradford, Steven P. Aggergaard, Bassford Remele, Minneapolis, MN; and Sherri C. Strand, Mark Sableman, Anthony F. Blum, Thompson Coburn, LLP, Saint Louis, MO, for amicus curiae The Lutheran Church–Missouri Synod.
In this case, we are presented with the question of whether pastors and their church can be held liable for statements the pastors made about a parishioner during formal church disciplinary proceedings. Appellants LaVonne and Henry Pfeil allege that they were defamed by the pastoral staff of St. Matthew Lutheran Church1 during two church disciplinary proceedings that were held for the purpose of excommunicating the Pfeils from St. Matthew. The district court dismissed the Pfeils’ claims with prejudice on First Amendment grounds, and the court of appeals affirmed. Because the First Amendment to the United States Constitution protects the right of a religious organization to make autonomous decisions regarding church discipline and membership, we affirm the district court’s dismissal of the claims.
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Had the court applied the Odenthal framework, it would have held that it could use neutral principles of law: Minnesota’s law of defamation. Then it would have analyzed the allegedly defamatory statements, one by one, to determine whether each could be resolved without excessive entanglement. Had it done so, it would have concluded that adjudicating most of the statements would be entangling. It also would have concluded that most were not actionable because they were matters of opinion. See, e.g., McKee v. Laurion, 825 N.W.2d 725, 733 (Minn.2013) (calling a physician a “real tool” is an opinion that cannot be the basis for a defamation action).