Payne-Elliott v. Roman Catholic Archdiocese of Indianapolis, Inc.Annotate this Case
The Supreme Court affirmed the judgment of the superior court dismissing this action under Indiana Trial Rule 12(B)(6) but modified the judgment to reflect that the dismissal was without prejudice, holding that the church-autonomy doctrine applied in this case and required its dismissal under Rule 12(B)(6).
Plaintiff sued the Roman Catholic Archdiocese of Indianapolis, Inc., asserting intentional interference with his contract and employment with Cathedral High School. The Archdiocese moved to the dismiss the complaint and invoked three defenses under the First Amendment, including the church-autonomy defense. The trial court dismissed the case with prejudice for failure to state a claim and for lack of subject-matter jurisdiction. The Supreme Court affirmed, holding that dismissal under Rule 12(B)(1) was improper but that the church-autonomy doctrine barred Plaintiff's claims.