Your mission, if you choose to accept it …

McRaney v. N. Am. Mission Board arises from a contentious dispute between the North American Mission Board, a Baptist organization, and the former executive director of the Baptist Convention of Maryland/Delaware (“BACM”). He alleged that the Board interfered with his employment relationship with BACM; the Board argued that it was protected by ecclesiastical immunity.

The case produced two difficult and intertwined legal issues: (1) the application of ecclesiastical immunity to the sprawling, decentralized structure of the various affiliates of the Southern Baptist Convention, and (2) the application of facially neutral tort principles to a job position with both secular and religious responsibilities (put another way, the plaintiff had to render unto both God and Caesar to do his job effectively). The panel majority presents some examples of the difficulty with the second issue:

“When a secular court considers the SPA, how should it determine if McRaney succeeded in ‘penetrating lostness,’ ‘making disciples,’ and ‘church planting’? Can a secular court determine whether NAMB’s conduct was the ‘proximate cause’ of BCMD’s decision to terminate McRaney, without unlawfully intruding on a religious organization’s internal management decisions? And can a secular court decide it was ‘false’ that McRaney’s leadership lacked Christ-like character?”

(citation omitted).

Echoing a close en banc vote after the denial of a motion to dismiss earlier in this litigation, the panel split 2-1, with the majority resolving the above issues in favor of the Board, and a dissent, in favor of the former director. No. 23-60494 (Sept. 9, 2025).

Attorneys who represent religious organizations should treat the majority opinion as a “compliance guide” to ensure that their organizations’ practices receive the full protection to which they may be entitled.