Little v. First Baptist Church, Crestwood

Background

In December 1982 a congregation elected a man to be pastor of a self-governing Baptist church in Virginia. In 1984 some members said the congregation had voted to fire him and sued to enforce that result. The pastor denied those members had authority to act for the church. The state trial court, relying on the pleadings, temporarily barred the pastor from church property, appointed a commissioner to hold a congregational election, and after the commissioner certified a vote to remove the pastor, issued a permanent injunction keeping him off the premises.

Reasoning

The Supreme Court declined to review the case, leaving the state court’s election and injunction in place. Justice Marshall, joined by Justice Brennan, dissented and said the trial court had gone too far. He explained courts must avoid entangling themselves in religious decisions and should use neutral, secular rules. Marshall said the trial court failed to follow that approach: it took the members’ word without evidence, did not check whether a meeting occurred or a quorum existed, and effectively caused the church to decide its own leadership question.

Real world impact

As a result of the denial, the state-court process and the permanent injunction remain effective, and the pastor remains excluded from church property. The Supreme Court did not decide the constitutional issue on the merits, so the legal question about court involvement in church governance could be revisited in a future case.

Dissents or concurrances

Justice Marshall’s dissent warns that this kind of court action risks violating the First Amendment by entangling government with church decisionmaking, and he would have granted review.