Winkler v. Marist Fathers of Detroit, Inc.

Defendant operated a parochial school to which plaintiff was denied admission. When plaintiff sued on the basis of disability discrimination, defendant moved for summary judgment, arguing among other things that, under the ecclesiastical abstention doctrine, the circuit court lacked subject matter jurisdiction over her claim. Central to defendant’s argument was Dlaikan v Roodbeen, 522 NW2d 719 (1994), which applied the doctrine to conclude that a circuit court had no such jurisdiction over a challenge to the admissions decisions of a parochial school. The circuit court denied defendant’s motion. The Court of Appeals, however, was convinced by defendant’s jurisdictional argument and reversed, thereby granting summary judgment in defendant’s favor. The Michigan Supreme Court disagreed with the appellate court’s determination: “[w]hile Dlaikan and some other decisions have characterized the ecclesiastical abstention doctrine as depriving civil courts of subject matter jurisdiction, it is clear from the doctrine’s origins and operation that this is not so. The ecclesiastical abstention doctrine may affect how a civil court exercises its subject matter jurisdiction over a given claim; it does not divest a court of such jurisdiction altogether. To the extent Dlaikan and other decisions are inconsistent with this understanding of the doctrine, they are overruled.” View "Winkler v. Marist Fathers of Detroit, Inc." on Justia Law