Puri v. Khalsa, No. 13-36024 (9th Cir. 2017)
Annotate this CasePlaintiffs, the widow and children of the late spiritual leader of the Sikh Dharma faith, filed suit against defendants, alleging claims related to the control of two nonprofit entities associated with the Sikh Dharma religious community. Plaintiffs alleged several interlocking conspiracies and fraudulent activities designed to exclude them from certain management positions and to convert millions of dollars in assets from entities under the individual defendants’ control for personal benefit. The district court dismissed the complaint and concluded that plaintiffs' claims were foreclosed by the Free Exercise and Establishment Clauses of the First Amendment. The court concluded, however, that based on the pleadings, plaintiffs' claims are not barred by the First Amendment’s ministerial exception and can be resolved by application of neutral principles of law without encroaching on religious organizations’ right of autonomy in matters of religious doctrine and administration. For the reasons stated in this opinion and in the concurrently filed memorandum disposition, the court vacated in part, affirmed in part, and remanded.
Court Description: First Amendment. The panel vacated the district court’s dismissal, as foreclosed by the Free Exercise and Establishment Clauses of the First Amendment, of claims concerning a dispute over the control of two nonprofit entities associated with the Sikh Dharma religious community. The panel held, based only on the pleadings, that the claims were not barred by the First Amendment’s ministerial exception. The panel held that the ecclesiastical abstention doctrine did not apply because the claims could be resolved by application of neutral principles of law without PURI V. KHALSA 3 encroaching on religious organizations’ right of autonomy in matters of religious doctrine and administration. The panel addressed additional issues in a concurrently filed memorandum disposition.
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