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Click here for the full text of this decision FACTS:Patton was employed by Oak Hill United Methodist Church as the director of youth ministries from April 2002 until Oct. 31, 2002. In that position, Patton was responsible for “the administration and organizing of recreational events for the youth, such as camping outings and other social gatherings. . . . [Patton] coordinated the transportation, . . . oversaw the logistics, . . . [and] served as a chaperone.” He also “managed the budget for the youth program, recruited [adult and youth] participants, registered the attendees at events, [] collected participation fees from attendees, [and] performed fundraising duties.” As director of youth ministries, Patton did not participate in worship services or ceremonies, had no responsibility for the music or liturgy, did not assist with the confirmation of youth, and was not required to teach religious classes or have religious training. On Oct. 24, 2002, appellee Kaye Jones (a pastor at St. John’s) discussed with appellee John Wright (an associate pastor at Oak Hill) whether Patton should be terminated from Oak Hill. According to handwritten notes taken by Wright, Jones told him about various allegations and rumors about Patton that had upset congregation members. Patton contends that each of the rumors are false. After this conversation, Wright relayed these rumors to appellee Barbara Ruth (a pastor at Oak Hill). Ruth then met with the staff parish relations committee and recommended that Patton be terminated from his position as Oak Hill’s director of youth ministries. Wright informed Patton of the decision. Shortly beforehand, Patton had discovered Wright’s handwritten notes laying on the church photocopy machine. In a subsequent letter to two concerned members of the congregation, the committee chairwoman wrote: “Please know that this committee and your pastors share your concern for the youth program. . . . A search for a new youth director will begin after the first of the year. . . . Before any action was taken, the Pastors discussed the situation with the District Superintendent and sought the backing of the SPRC . . . [which] unanimously voted to accept the recommendation to support the decision reached by [Jones], [Wright], and myself. . . . I can assure you that [we] approached this decision prayerfully and in the best interests of the church. . . .” Patton also alleged that the chairwoman told a member of the congregation who asked about Patton’s termination that, “It is really bad” and “We had to get him out before something happened at our church,” and that Ruth responded to a member’s question by stating, “[Patton] knows why he was fired” and “he wouldn’t want anyone else to know.” Patton sued the church, claiming it was liable for defamation and tortious interference with an employment contract. The church defendants filed a joint motion to dismiss, which was granted by the trial court. This appeal followed. The sole question presented on appeal is whether, based on First Amendment principles, the trial court correctly determined that it lacked subject matter jurisdiction. HOLDING:Affirmed in part and reversed and remanded in part. If Patton’s job function was ministerial, then his claims for defamation and tortious interference are not subject to secular review to the extent that they are connected to the church’s decision to terminate his employment. The court does not find any case presenting the exact question here � whether a director of youth ministries, who does not preach or teach but instead administers and oversees the church’s youth-group activities and fundraising, holds a ministerial position. Considering the primary duties test of Starkman v. Evans, 198 F.3d 173 (5th Cir. 1999), the court finds 1. The church’s employment decision regarding Patton’s position would be based largely on religious criteria and 2. Patton’s organizing of, as well as his budgeting, fundraising and recruiting participants for youth ministry activities are things traditionally considered to serve an ecclesiastical or religious purpose. The court holds that, as director of the youth ministry for the United Methodist church, Patton functioned in a ministerial capacity. Thus, the trial court was correct to dismiss for a lack of subject matter jurisdiction Patton’s claims for 1. tortious interference with his employment contract and 2. defamation, to the extent that it was based on statements made in furtherance of the church’s decision to terminate Patton. Because the statements contained in the chairwoman’s letter and made in response to the congregation members’ questions were outside the bounds of the church’s employment decision, they do not appear to be of an ecclesiastic nature, the court states, and therefore should not have been dismissed for lack of subject matter jurisdiction. Nonetheless, the court cautions the trial court to abstain from a review of ecclesiastical issues. OPINION:Law, C.J.; Law, C.J., Patterson and Puryear, J.J.

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