Orr Not: Ecclesiastical Abstention Doctrine Bars Pastor’s Claims Arising from Internal Sexual Harassment Investigation

Illinois Courts continue to respect ecclesiastical boundaries in matters of internal church governance. This year, an Illinois court ruled a pastor disciplined for sexual harassment could not seek judicial relief arising from his church denomination’s internal investigation of a sexual harassment claim against him. Instead, the court deferred to the religious institution’s internal mechanisms as a matter of First Amendment “ecclesiastical abstention,” since all statements at issue were made within such internal church proceedings.