T. Farrar Patterson v. Southwestern Baptist Theological Seminary

T. Farrar Patterson (Patterson), appeals a summary judgment denying him recovery in his wrongful termination suit against Southwestern Baptist Theological Seminary (Seminary). The trial court granted summary judgment on the ground that under the First and Fourteenth Amendments to the United States Constitution and Article 1, Section 6 of the Texas Constitution, the decisions of religious organizations regarding ecclesiastical matters must be accepted by the trial court. Patterson contends the trial court erred in its judgment because genuine issues of fact exist as to: whether a seminary is a "church"; whether the dispute concerns ecclesiastical matters; and whether Pattersons procedural and substantive rights under the Seminary bylaws have been violated. Because this case essentially involves a religious dispute, the resolution of which is for ecclesiastical tribunals, we overrule Pattersons points of error and affirm the trial courts judgment.