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Winkler v. Marist Fathers of Detroit, Inc.

Supreme Court of Michigan

June 27, 2017

BETTINA WINKLER, by her next friends HELGA DAHM WINKLER and MARVIN WINKLER, Plaintiff-Appellant,
v.
MARIST FATHERS OF DETROIT, INC., d/b/a NOTRE DAME PREPARATORY HIGH SCHOOL AND MARIST ACADEMY, Defendant-Appellee.

          Argued on application for leave to appeal April 13, 2017.

          Chief Justice: Stephen J. Markman, Justices Brian K. Zahra Bridget M. McCormack David F. Viviano Richard H. Bernstein Joan L. Larsen Kurtis T. Wilder.

         Syllabus

         Bettina Winkler brought an action in the Oakland Circuit Court, alleging that Marist Fathers of Detroit, Inc., denied her admission to its high school because of her learning disability, in violation of MCL 371.1402 of the Persons with Disabilities Civil Rights Act (PWDCRA), MCL 371.1101 et seq. Plaintiff attended the middle school division of Notre Dame Preparatory High School and Marist Academy, but defendant denied her admission to the high school division of its school. Defendant moved for summary disposition under MCR 2.116(C)(4) and (10), arguing that under the ecclesiastical abstention doctrine, the circuit court lacked subject-matter jurisdiction to review the admission decision of a religious school, that the PWDCRA does not apply to religious schools, and that even if the act did apply to defendant, there was no genuine dispute that defendant's decision was based on plaintiff's academic record, not her learning disability; plaintiff sought a preliminary injunction. The court, Rudy J. Nichols, J., denied defendant's (C)(4) motion, concluding that it had subject-matter jurisdiction over plaintiff's PWDCRA claim. The court also denied defendant's (C)(10) motion, reasoning that it was premature because discovery had just started and that plaintiff had failed to establish that the PWDCRA does not apply to religious schools. The court also denied plaintiff's request for a preliminary injunction. Defendant appealed. In an unpublished per curiam opinion issued November 12, 2015 (Docket No. 323511), the Court of Appeals, Sawyer, P.J., and K. F. Kelly and Fort Hood, JJ., reversed the trial court's order and remanded the case to the trial court for entry of summary disposition in favor of defendant under MCR 2.116(C)(4). Relying on Dlaikan v Roodbeen, 206 Mich.App. 591 (1994), the Court of Appeals concluded that under the First Amendment, the trial court lacked subject-matter jurisdiction to review defendant's admission decision, reasoning that courts may not analyze the decision-making process of a religious institution. The Court of Appeals accordingly declined to address defendant's argument that the PWDCRA does not apply to religious schools and defendant's remaining (C)(10) arguments that were not resolved by the trial court. Plaintiff sought leave to appeal. The Supreme Court ordered and heard oral argument on whether to grant plaintiff's application for leave to appeal or take other action, and it directed the parties to address: (1) whether the doctrine of ecclesiastical abstention involves a question of a court's subject-matter jurisdiction over a complaint, (2) whether the Court of Appeals correctly concluded that consideration of plaintiff's challenge to defendant's admission decision would have impermissibly entangled the trial court in questions of religious doctrine or ecclesiastical polity, and (3) whether the Supreme Court should overrule Dlaikan, and if so on what basis. 500 Mich. 888 (2016).

         In a unanimous opinion by Justice McCormack, in lieu of granting leave to appeal, the Supreme Court held:

         The ecclesiastical abstention doctrine informs how a civil court must adjudicate claims within its subject-matter jurisdiction that involve ecclesiastical questions; it does not operate to divest courts of subject-matter jurisdiction over such claims. Dlaikan was overruled to the extent it held otherwise.

         1. Subject-matter jurisdiction is the right of a court to exercise judicial power over a certain class of cases; the court's jurisdiction is not dependent on the particular facts of a case or whether a plaintiff has a cause of action. MCL 600.605 provides that Michigan circuit courts are courts of general jurisdiction, and those courts have original jurisdiction to hear and determine all civil claims and remedies, with the exception of when exclusive jurisdiction is given in the constitution or by statute to some other court or when circuit courts are denied jurisdiction by Michigan's 1963 Constitution or Michigan statutes. Accordingly, circuit courts have subject-matter jurisdiction over claims of discrimination under the PWDCRA.

         2. The ecclesiastical abstention doctrine, which arises from the Religion Clauses of the First Amendment of the United States Constitution, prohibits a civil court from substituting its opinion for that of the authorized tribunal of a religious entity in ecclesiastical matters, or from otherwise judicially interfering in the purely ecclesiastical affairs of a religious entity. While the doctrine thus ensures that a civil court, when adjudicating a particular case, does not infringe on the religious freedoms and protections guaranteed under the First Amendment, it does not deprive civil courts of the right to exercise judicial power over any given class of cases. In other words, the ecclesiastical abstention doctrine does not divest courts of jurisdiction over every claim or case involving an ecclesiastical question. Instead, the doctrine requires a case-specific inquiry that informs how a court must adjudicate claims within its subject-matter jurisdiction that involve such questions; it is not applied to determine whether the court has subject-matter jurisdiction over those claims in the first place. In this case, the ecclesiastical abstention doctrine did not divest the trial court of subject-matter jurisdiction to hear plaintiff's PWDCRA claim; the court has judicial power to consider and dispose of the claim in a manner consistent with First Amendment guarantees. Accordingly, the Court of Appeals erred by reversing the trial court's order and remanding for entry of summary disposition in favor of defendant under MCR 2.116(C)(4). To the extent Dlaikan and other cases hold that the ecclesiastical abstention doctrine affects a court's subject-matter jurisdiction over a particular case, those decisions are overruled.

         Court of Appeals judgment reversed and the case remanded to the Court of Appeals for consideration of defendant's argument that the PWDCRA does not apply to its school.

         BEFORE THE ENTIRE BENCH

          OPINION

          McCormack, J.

         When presented with an ecclesiastical question, civil courts have long recognized the need, grounded in the First Amendment, to abstain from answering it themselves. This case invites us to consider the nature of this ecclesiastical abstention doctrine: namely, whether it is properly understood as a limitation on the subject matter jurisdiction of civil courts. The defendant operates a parochial school to which the plaintiff was denied admission. When the plaintiff sued on the basis of disability discrimination, the defendant moved for summary disposition, arguing among other things that, under the ecclesiastical abstention doctrine, the circuit court lacked subject matter jurisdiction over her claim. Central to the defendant's argument was Dlaikan v. Roodbeen, 206 Mich.App. 591; 522 N.W.2d 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 the defendant's motion. The Court of Appeals, however, was convinced by the defendant's jurisdictional argument and reversed the circuit court, awarding the defendant summary disposition under MCR 2.116(C)(4).

         We disagree with this determination. While 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. We therefore reverse the Court of Appeals' award of summary disposition to the defendant under MCR 2.116(C)(4), and we remand to that Court for further proceedings.

         I

         The defendant, Marist Fathers of Detroit, Inc., operates Notre Dame Preparatory High School and Marist Academy (NDPMA), a private, Catholic school in Oakland County. The plaintiff, Bettina Winkler, is a young woman who attended the middle-school division of NDPMA, but was denied admission to its high school. Believing this decision was based on her learning disability, dyslexia, the plaintiff filed suit, alleging that the defendant violated MCL 37.1402 of the Persons With Disabilities Civil Rights Act (PWDCRA), MCL 37.1101 et seq.[1] Motions ensued, with the plaintiff requesting a preliminary injunction and the defendant seeking summary disposition under MCR 2.116(C)(4) and (C)(10). As is relevant here, the defendant argued that, under the ecclesiastical abstention doctrine-and, more specifically, its application in Dlaikan-the circuit court could not exercise subject matter jurisdiction over a challenge, such as the plaintiff's, to the admissions decision of a religious school. The defendant further argued that the ...


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