COA 371028 REV DR MARCUS L LOVELACE V MT ZION BAPTIST CHURCH Opinion - Per Curiam - Unpublished 7/15/2026

371028Court Of Appeals15.07.2026

Gesamter Gesetzestext

If this opinion indicates that it is “FOR PUBLICATION,” it is subject to
revision until final publication in the Michigan Appeals Reports.
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S T A T E O F M I C H I G A N
C O U R T O F A P P E A L S
REV. DR. MARCUS L. LOVELACE,
Plaintiff-Appellant,
UNPUBLISHED
July 15, 2026
11:45 AM
v No. 371028
Wayne Circuit Court
MT. ZION BAPTIST CHURCH,
CLEOTHA SIMS, JAMES COOLEY,
JAMES TWYMAN, and MARGIE
BRAXTON,
LC No. 22-005770-CZ
Defendants-Appellees.
Before: RICK, P.J., and MURRAY and BORRELLO, JJ.
PER CURIAM.
In this employment dispute, plaintiff, the former senior pastor of defendant, Mt. Zion
Baptist Church (the church), appeals as of right the trial court’s orders dismissing his case. We
affirm.
I. FACTUAL BACKGROUND
This case arises from the church’s decision to terminate plaintiff as its senior pastor. Before
plaintiff began his tenure, the church’s executive board, consisting of defendants Cleotha Sims,
James Cooley, James Twyman, and Margie Braxton, began searching for a new senior pastor after
the position had been vacant for three years. Plaintiff applied, as did several other candidates.
Plaintiff alleges that the individual defendants opposed his candidacy and supported another
candidate. Nevertheless, the congregation voted to elect plaintiff as senior pastor.
Plaintiff and the church entered into an employment agreement in September 2021.
Twyman signed the agreement on behalf of the church as chairman of the deacon board. Cooley,
a trustee, also signed the agreement. The agreement included a signature line for Braxton, also a
trustee, but she did not sign. Sims was not a signatory. The employment agreement gave plaintiff
broad authority to lead the church as the “shepherd and overseer of all day-to-day operations and
administration of the church.” The church’s leadership agreed to “work in conjunction with him
to accomplish his vision that he has laid out for the growth of the church.” The agreement also

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provided that the church could terminate the agreement for cause if plaintiff committed “any
serious offense which would constitute a felony under the law.” The agreement further provided
that the church could terminate plaintiff’s employment for reasons other than cause following a
vote of the church’s members.
The relationship between plaintiff and defendants deteriorated soon after plaintiff began
serving as senior pastor. Plaintiff alleged that he discovered irregularities in the church’s finances.
Plaintiff also began making changes to the church’s leadership and personnel, which he believed
fell within the broad authority granted to him in his employment agreement. At a church service
in March 2022, Braxton announced that there would be a special meeting on April 2, 2022, to
discuss plaintiff’s alleged abuse of power. The meeting agenda included motions to reverse some
of plaintiff’s personnel changes and some of his changes to the church’s financial accounts. At a
second meeting on April 9, 2022, the church members present voted to dismiss plaintiff as pastor
and cancel his employment contract.
Plaintiff then filed this action. He alleged breach of contract against the church (Count I),
intentional interference with contractual relations against the individual defendants (Count II), and
defamation and defamation per se against the individual defendants (Count III).
In lieu of an answer, defendants moved for summary disposition of all claims under
MCR 2.116(C)(8) (failure to state a claim) and MCR 2.116(C)(10) (no genuine issue of material
fact). Defendants argued that the decision to terminate plaintiff was ecclesiastical and that the
court could not second-guess the church’s internal decisions. Because all three claims arose from
plaintiff’s employment and duties as pastor, defendants argued that the complaint should be
dismissed in its entirety under the ecclesiastical abstention doctrine. The trial court entered a
written order denying defendants’ motion for summary disposition with prejudice under
MCR 2.116(C)(4) (court lacks subject-matter jurisdiction)1 and (C)(8), and denying the motion
without prejudice under MCR 2.116(C)(10).
After discovery closed, defendants filed a second motion for summary disposition, this
time under MCR 2.116(C)(7) (immunity granted by law) and (C)(10). Defendants again argued
that plaintiff’s claims could not be adjudicated by a civil court because they were barred by the
ecclesiastical abstention doctrine. Defendants also argued that plaintiff’s exclusive forum to
challenge the merits of the termination decision was the April 9, 2022 congregational meeting. At
the hearing, the trial court reasoned that the breach-of-contract claim would require the court to
decide internal matters of church policy, which it could not do. The court concluded, however,
that the tort claims against the individual defendants were not barred by the ecclesiastical
abstention doctrine.
The matter was scheduled for trial. Before trial, defendants filed a motion in limine that
largely repeated the arguments raised in their summary-disposition motions and asked the court to
dismiss Counts II and III under the ecclesiastical abstention doctrine. Regarding tortious
1 Defendants filed a motion for reconsideration arguing, in part, that they did not move for
summary disposition under MCR 2.116(C)(4) and so the court should not have included this in its
opinion, but the court denied the motion.

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interference, the trial court concluded that plaintiff would have to show either a per se wrongful
act or a lawful act done with malice and without legal justification. The court further concluded
that, even if plaintiff could establish intentional interference, it would have to decide issues
concerning the church’s authority, which it once again could not do. The court therefore dismissed
Count II. The court also dismissed plaintiff’s defamation claim, reasoning that the statement that
plaintiff abused his power was opinion and therefore not actionable. The court further reasoned
that the statements were made only during the church meeting held to decide whether plaintiff’s
employment should be terminated and were therefore barred from civil review by the ecclesiastical
abstention doctrine. Finally, the court concluded that plaintiff was a public figure and that he could
not show the requisite malice, and it dismissed the last of plaintiff’s claims. This appeal followed.
II. ANALYSIS
A. STANDARDS OF REVIEW
We review issues of constitutional law de novo. Winkler by Winkler v Marist Fathers of
Detroit, Inc, 500 Mich 327, 333; 901 NW2d 566 (2017). We also review de novo the interpretation
of a contract. Rory v Continental Ins Co, 473 Mich 457, 464; 703 NW2d 23 (2005).
We likewise review a trial court’s decision to grant or deny a motion for summary
disposition de novo. Id. The trial court dismissed Count I of plaintiff’s complaint under
MCR 2.116(C)(10). “A motion under MCR 2.116(C)(10) tests the factual sufficiency of the
complaint.” Maiden v Rozwood, 461 Mich 109, 120; 597 NW2d 817 (1999). When reviewing a
motion brought under MCR 2.116(C)(10), the trial court considers affidavits, pleadings,
depositions, admissions, and documentary evidence filed or submitted by the parties in the light
most favorable to the nonmoving party. Quinto v Cross & Peters Co, 451 Mich 358, 362; 547
NW2d 314 (1996). If the moving party meets its initial burden, “[t]he burden then shifts to the
opposing party to establish that a genuine issue of disputed fact exists.” Id. When the nonmoving
party has the burden of proof at trial, it must submit evidence that demonstrates a genuine issue of
material fact exists and may not rest on mere allegations or denials in the pleadings. Id. at 362-
363. “If the opposing party fails to present documentary evidence establishing the existence of a
material factual dispute, the motion is properly granted.” Id. at 363. In other words, “[i]f no facts
are in dispute, and if reasonable minds could not differ regarding the legal effect of those facts,
whether summary disposition is proper is a question of law for the Court.” Estate of Miller v
Angels’ Place, Inc, 334 Mich App 325, 330; 964 NW2d 839 (2020).
The trial court dismissed Counts II and III of the complaint when deciding a motion in
limine, but the court also indicated on the record that it was doing so as the trier of fact. “A trial
court’s decision on a motion in limine is reviewed for an abuse of discretion.” Law Offices of
Jeffrey Sherbow, PC v Fieger & Fieger, PC, 347 Mich App 533, 550; 15 NW3d 356 (2023). When
the inquiry involves the proper application of legal principles, this aspect of the decision is
reviewed de novo. Id.
“A trial court’s findings of fact in a bench trial are reviewed for clear error while its
conclusions of law are reviewed de novo.” Midwest Valve & Fitting Co v Detroit, 347 Mich App
237, 250; 14 NW3d 826 (2023), aff’d on other grounds 516 Mich 909 (2024).

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B. BREACH OF CONTRACT
Plaintiff argues that the trial court erred by dismissing his breach-of-contract claim under
the ecclesiastical abstention doctrine. We disagree.
The First Amendment of the United States Constitution provides that “Congress shall make
no law respecting an establishment of religion, or prohibiting the free exercise thereof . . . .” US
Const, Am I. “The First Amendment applies to the states through the Fourteenth Amendment.”
Weishuhn v Catholic Diocese of Lansing, 279 Mich App 150, 156; 756 NW2d 483 (2008). The
Michigan Constitution likewise guarantees freedom of worship and religious belief. See Const
1963, art 1, § 4. The Michigan Constitution is “at least as protective of religious liberty as the
United States Constitution.” Winkler, 500 Mich at 337 n 4 (quotation marks and citation omitted).
The ecclesiastical abstention doctrine “arises from the Religion Clauses of the First
Amendment of the United States Constitution.” Id. at 337. The doctrine provides that it would be
inconsistent with complete and untrammeled religious liberty for civil courts to
enter into a consideration of church doctrine or church discipline, to inquire into
the regularity of the proceedings of church tribunals having cognizance of such
matters, or to determine whether a resolution was passed in accordance with the
canon law of the church, except insofar as it may be necessary to do so, in
determining whether or not it was the church that acted therein. [Id. at 337-338
(quotation marks and citation omitted).]
Under the ecclesiastical abstention doctrine, courts have consistently held that “judicial
interference in the purely ecclesiastical affairs of religious organizations is improper.” Id. at 338
(quotation marks and citation omitted).
The ecclesiastical abstention doctrine provides that civil courts are “severely circumscribed
by the First and Fourteenth Amendments to the United States Constitution and art 1, § 4 of the
Michigan Constitution of 1963 in resolution of disputes between a church and its members.”
Pilgrim’s Rest Baptist Church v Pearson, 310 Mich App 318, 323; 872 NW2d 16 (2015) (quotation
marks and citation omitted), overruled in part by Winkler, 500 Mich at 337-340.2 Additionally,
when a pastor sues a church based on his employment contract and “the claim involves the
provision of the very services . . . for which the organization enjoys First Amendment protection,
2 In Pilgrim’s Rest, this Court characterized the ecclesiastical abstention doctrine as a limitation
on the subject matter jurisdiction of civil courts. Pilgrim’s Rest, 310 Mich App at 323-324.
However, in Winkler, the Supreme Court clarified that the ecclesiastical abstention doctrine does
not limit a civil court’s subject matter jurisdiction because it is not determined by reference to the
category or class of the case the plaintiff has stated but rather it “requires a case-specific inquiry
that informs how a court must adjudicate certain claims within its subject matter jurisdiction; it
does not determine whether the court has such jurisdiction in the first place.” Winkler, 500 Mich
at 341.

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then any claimed contract for such services likely involves its ecclesiastical policies, outside the
purview of civil law.” Id. at 324 (quotation marks and citation omitted).
Although the doctrine requires civil courts to defer to religious bodies on ecclesiastical
questions, it does not completely deprive civil courts of subject-matter jurisdiction over such cases.
Winkler, 500 Mich at 337-338. However, if “the actual adjudication of a particular legal claim
would require the resolution of ecclesiastical questions . . . the court must abstain from resolving
those questions itself, defer to the religious entity’s resolution of such questions, and adjudicate
the claim accordingly.” Id.
The related “ministerial exception” to employment-discrimination law “has its roots in the
First Amendment’s guarantees of religious freedom and, generally, it bars any inquiry into a
religious organization’s underlying motivation for [a] contested employment decision.”
Weishuhn, 279 Mich App at 157 (citations and quotation marks omitted). The exception bars
employment-discrimination claims based on federal civil-rights statutes and related common-law
claims. Id.
To prove his breach-of-contract claim, plaintiff had to establish: (1) there was a contract,
(2) defendants breached the contract, and (3) the breach resulted in damages. Miller-Davis Co v
Ahrens Constr, Inc, 495 Mich 161, 178; 848 NW2d 95 (2014). In response to defendants’ second
motion for summary disposition, plaintiff asserted two theories of breach: “First, by organizing,
announcing, and holding the April 2 and 9, 2022 meetings in violation of the Contract. Second,
by terminating [plaintiff’s] employment for actions that were well within the scope of his
contractual rights.” Under Winkler, the question is whether adjudicating either theory would
require a civil court to resolve ecclesiastical questions reserved to the church. Both theories would
require that inquiry, and the trial court properly abstained.
We first address plaintiff’s second theory, namely that the church breached the agreement
by terminating him for actions he was contractually permitted to take. This theory would require
a civil court to decide whether church leadership correctly concluded that plaintiff had “abused his
authority” when he took actions that he believed were within his authority as the “shepherd and
overseer of all day-to-day operations and administration of the church.” That inquiry would
require the court to decide questions of church governance and authority. “Under the ecclesiastical
abstention doctrine, apparently derived from both First Amendment religion clauses, civil courts
may not redetermine the correctness of an interpretation of canonical text or some decision relating
to government of the religious polity.” Smith v Calvary Christian Church, 462 Mich 679, 684;
614 NW2d 590 (2000) (citation and quotation marks omitted; emphasis added). The church, not
a civil court, must decide how it will organize itself and how much authority its senior pastor may
exercise over religious and secular affairs. The church’s leadership and members made that
decision here, and we will not disturb it.
This theory also fails for a more basic reason. Plaintiff’s argument assumes that he could
not be terminated if he acted within the authority granted by the employment agreement. But the
agreement permitted the church to terminate plaintiff for cause and for reasons other than cause,
provided that certain procedural requirements were met. The church therefore did not breach the
agreement merely by terminating plaintiff for actions that he believed were within the agreement’s
grant of authority.

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Plaintiff’s other theory, that the church breached the agreement by terminating him without
following the process required for termination without cause, presents a closer question. Plaintiff
relies in part on Vincent v Raglin, 114 Mich App 242; 318 NW2d 629 (1982), which he contends
is factually analogous. In Vincent, a pastor sued church deacons and trustees for conspiring to
deprive him unlawfully of the economic benefits of his pastorate after a rift developed in the
church. Id. at 245-246. At the close of the plaintiff’s proofs, the trial court entered a directed
verdict for the defendants, holding that the separation of church and state barred judicial review of
the plaintiff’s claims. Id. at 246. This Court reversed, holding that civil courts had a duty to
determine when, if ever, the church terminated the plaintiff’s duties as pastor. Id. at 247. The
Court remanded for a jury to determine whether the vote, which apparently included both members
and nonmembers, constituted an action of the church under the church’s governing documents. Id.
at 249. The Court emphasized, “once again, that a controversy involving a church is not immune
from judicial review unless adjudication of the controversy would require an assessment of the
propriety of an action by the church.” Id. at 252.
But later decisions have made clear that Vincent’s holding is limited. In Vincent, the Court
held that civil courts could determine whether a church had actually terminated a pastor. Pilgrim’s
Rest, 310 Mich App at 324. When a party asks a civil court to determine whether a church
exceeded its authority in firing a clergyman, the question is “nonjusticiable because it would
require the court to determine if the church violated its own policy.” Id.
Here, plaintiff asks us to determine that the church and its leadership exceeded their
authority when they called the April 2022 meetings to discuss his future as senior pastor and
invited guest pastors to oversee those meetings despite (1) the requirement in the employment
agreement that church leadership work with the pastor to accomplish his vision, (2) the provision
giving the pastor responsibility for the functioning of the church, and (3) the provision that no
person could be invited to speak, preach, teach, or minister in any fashion at any service or meeting
without plaintiff’s approval. Under the ecclesiastical abstention doctrine, a civil court may not
decide those questions because it would generally be inconsistent with religious liberty for civil
courts to “inquire into the regularity of the proceedings of church tribunals having cognizance of
such matters, or to determine whether a resolution was passed in accordance with the canon law
of the church.” Winkler, 500 Mich at 338 (quotation marks and citations omitted). Plaintiff does
not dispute that the church acted to terminate his employment. He disputes whether the church
and its leadership exceeded their authority in doing so. That question is not for the courts.
Nor can this dispute be resolved through neutral principles of contract law. Plaintiff argues
that the trial court could have interpreted the termination provisions of his contract without
deciding matters of religious doctrine. But plaintiff also identifies ambiguities in the termination
provision itself. Specifically, the terms “the congregation of the church,” “Church Body,” and
“eligible members” all appear in the provision governing termination for reasons other than cause,
and none is defined.
Twyman testified that, to become a member of the church, a person needed only to
acknowledge that he or she wanted to become a member. He also testified that a “prior discussion
was held as it relates to whether [a] person is an actual member” for voting purposes, and those
discussions involved whether the person had recently attended the church and whether the person
financially supported the church. Church leadership decided “if there was no visitation from the

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member or gifts given within 90 days of that, of a certain time, he wouldn’t be eligible to be
considered as a member.”
Plaintiff seeks a remand so that a civil court can determine whether the “ ‘the congregation
of the church’ or the ‘Church Body’ wished to terminate his employment without cause” under the
termination provision. But answering that question would require the court to decide matters at
the center of the church’s organization and mission: who is a member of the church, whether a
profession of faith is required, which religious tenets a prospective member must accept, whether
baptism or another act is required for membership, whether only a subset of members may vote on
matters affecting the church’s future, and what qualities define that subset. Civil courts may not
answer those questions without intruding on the church’s religious liberty. See White v Mount
Beulah Baptist Church, 319 Mich 392, 394; 29 NW2d 774 (1947) (reversing the trial court’s order
outlining a process wherein the court would have determined the membership of the church for
the purposes of a church election). See also Berry v Bruce, 317 Mich 490, 498; 27 NW2d 67
(1947) (reversing the trial court’s order which directed that a church meeting be held and
determined who would be permitted to take part in the meeting).
In short, even the seemingly straightforward question whether the termination process in
plaintiff’s employment agreement was followed cannot be answered here through neutral legal
principles without infringing on the religious liberty of the church and its members. Accordingly,
the trial court correctly dismissed Count I.
C. INTENTIONAL INTERFERENCE WITH CONTRACTUAL RELATIONS
Plaintiff next argues that the trial court erred by dismissing his claim for intentional
interference with contractual relations. We disagree.
To prove tortious interference with a contract or contractual relations, a plaintiff must
demonstrate “(1) the existence of a contract, (2) a breach of the contract, and (3) an unjustified
instigation of the breach by the defendant, resulting in damage to the aggrieved party to the
contract.” Int’l Outdoor, Inc v SS Mitx, LLC, 349 Mich App 212, 237; 27 NW3d 365 (2023)
(quotation marks and citation omitted). As to the second element, “the element of breach may be
demonstrated by showing that the defendant induced or otherwise caused nonperformance of the
contract.” Id. (quotation marks and citation omitted). Regarding the third element,
the party alleging tortious interference with a contractual relationship must allege
the intentional doing of a per se wrongful act or the doing of a lawful act with
malice and unjustified in law for the purpose of invading the contractual rights of
another. If the defendant’s conduct was not wrongful per se, the plaintiff must
demonstrate specific, affirmative acts that corroborate the unlawful purpose of the
interference. [Id. at 237-238 (quotation marks and citations omitted).]
But a plaintiff cannot maintain a tortious-interference claim against a party to the contract.
Derderian v Genesys Health Care Sys, 263 Mich App 364, 382; 689 NW2d 145 (2004). Thus,
“the plaintiff must establish that the defendant was a ‘third party’ to the contract rather than an
agent of one of the parties acting within the scope of its authority as an agent.” Lawsuit Fin, LLC
v Curry, 261 Mich App 579, 593; 683 NW2d 233 (2004). Corporate agents are not liable for

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tortious interference with the corporation’s contracts unless they acted solely for their own benefit
with no benefit to the corporation. Reed v Mich Metro Girl Scout Council, 201 Mich App 10, 13;
506 NW2d 231 (1993).
That threshold requirement is dispositive here. Plaintiff’s employment agreement was
between himself and the church. The individual defendants were not strangers to that contractual
relationship. Twyman signed the agreement on behalf of the church as chairman of the deacon
board, and Cooley signed the agreement as a trustee. Although Sims did not sign the agreement,
and Braxton’s signature line was left unsigned, plaintiff’s claim is based on actions the individual
defendants allegedly took as church officers, trustees, deacons, or members of church leadership.
Plaintiff alleged that the individual defendants opposed his leadership, organized or participated
in the April 2022 church meetings, sought to reverse his personnel and financial decisions, and
placed before the congregation the question whether he should continue serving as senior pastor.
Those allegations concern actions taken through the church’s internal leadership structure and
congregational process in connection with the church’s own decision whether to continue its
contractual relationship with plaintiff. On those facts, plaintiff cannot establish that the individual
defendants were third parties to the church’s employment agreement.
Nor has plaintiff established that the individual defendants acted solely for their own
benefit and with no benefit to the church. Id. at 13. Plaintiff alleged that the individual defendants
opposed his candidacy, disagreed with his decisions as senior pastor, and sought to undo actions
that he believed were within his contractual authority. But those allegations do not establish that
the individual defendants acted solely for private benefit. At most, they show a dispute between
plaintiff and church leadership over who had authority to govern the church’s affairs and whether
plaintiff should remain the church’s senior pastor. To the extent plaintiff argues that the individual
defendants acted outside their authority or for illegitimate reasons, that argument would require a
civil court to decide whether the individual defendants’ actions were proper under the church’s
internal governance structure and whether their stated concerns about plaintiff’s leadership were
legitimate. Those are precisely the types of ecclesiastical questions civil courts may not decide.
See Winkler, 500 Mich at 341.
For similar reasons, plaintiff cannot avoid dismissal by focusing on the remaining elements
of tortious interference. To establish breach, plaintiff would have to show that the church failed
to comply with the employment agreement when it terminated him. As already explained, even
the narrow question whether the termination procedure was properly followed cannot be answered
here through neutral principles of law because it would require a civil court to decide who qualified
as an eligible church member and whether the church’s internal meeting and voting procedures
were valid. And to establish unjustified interference, plaintiff would have to show that the
individual defendants acted with malice and without legal justification when they sought his
removal. That inquiry would require a civil court to decide whether the individual defendants were
justified in believing that plaintiff had abused his authority and should no longer lead the church.
Under the ecclesiastical abstention doctrine, that question belongs to the church, not the courts.
Accordingly, plaintiff’s tortious-interference claim fails because he cannot establish that
the individual defendants were third parties to the employment agreement. And even if plaintiff
could satisfy that threshold requirement, adjudicating the breach and justification elements of his
claim would require the resolution of ecclesiastical questions. Plaintiff’s claim thus fails.

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D. DEFAMATION
Finally, plaintiff argues that the trial court erred by dismissing his defamation claim, either
for failure to state a claim or under the ecclesiastical abstention doctrine. We disagree.
Under Michigan law, there are four basic elements of a defamation claim:
(1) a false and defamatory statement concerning the plaintiff, (2) an unprivileged
communication to a third party, (3) fault amounting at least to negligence on the
part of the publisher, and (4) either actionability of the statement irrespective of
special harm (defamation per se) or the existence of special harm caused by
publication. [Ghanam v Does, 303 Mich App 522, 544; 845 NW2d 128 (2014)
(citations and quotation marks omitted).]
To state a claim for defamation, a plaintiff must “plead a defamation claim with specificity by
identifying the exact language that the plaintiff alleges to be defamatory.” Sarkar v Doe, 318 Mich
App 156, 184; 897 NW2d 207 (2016) (quotation marks and citation omitted).
A statement is defamatory “if it tends to lower an individual’s reputation in the community
or deter[] third persons from associating or dealing with that individual.” Reighard v ESPN, Inc,
341 Mich App 526, 538; 991 NW2d 803 (2022) (quotation marks and citation omitted). But “[i]f
a statement cannot be reasonably interpreted as stating actual facts about the plaintiff, it is protected
by the First Amendment.” Id. (quotation marks and citation omitted). Thus, “at least some
expressions of opinion are protected.” Id. (quotation marks and citation omitted). To be
defamatory, the statement must assert facts that are “provable as false.” Sarkar, 318 Mich App
at 179.
Plaintiff alleged the following in support of his defamation claim: “During the April 2,
2022 meeting, Mr. Sims, Mr. Cooley, Ms. Braxton, Mr. Twyman, and perhaps others, falsely
accused Pastor of Lovelace [sic] of ‘abusing his power’ by ‘[a]ttempting to gain access to [Church
bank accounts] on Friday, March 18, 2022.’ ” The trial court concluded that plaintiff failed to state
a defamation claim because the allegation was constitutionally protected opinion. The trial court
also concluded that, because plaintiff was a public figure, his claim failed for the additional reason
that he could not prove actual malice.
We do not agree with the trial court’s reasoning that the allegedly defamatory statement
was not provable as false. Plaintiff’s defamation theory is that the individual defendants stated
that he lacked authority to access the church’s bank accounts, and that this statement was false
because his employment agreement gave him broad authority over the church’s spiritual and
secular affairs. At least in theory, one could determine whether that statement was true or false by
examining whether the employment agreement granted plaintiff that authority.
For the statement to be actionable, however, a civil court would have to determine that it
was false. Ghanam, 303 Mich App at 544. The statement at issue, namely that plaintiff exceeded
his authority as senior pastor under the employment agreement, would be provable as false only if
the trial court parsed the agreement and determined which powers belonged to the senior pastor.
As explained, the trial court could not review the scope of plaintiff’s authority under the
employment agreement because “civil courts may not redetermine the correctness of . . . some

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decision relating to government of the religious polity.” Smith, 462 Mich at 684 (emphasis added;
quotation marks and citation omitted). Plaintiff maintains that the agreement authorized him to
access the church’s bank accounts. Church leadership maintained that it did not. That dispute
concerns church polity, and it must be resolved by the church. Holt v Trone, 341 Mich 169, 174;
67 NW2d 125 (1954) (“In matters of church polity purely ecclesiastical[,] civil courts do not
interfere . . . .”) (citation and quotation marks omitted).
Accordingly, although we do not agree with the trial court’s conclusion that the allegedly
defamatory remarks in paragraph 57 of plaintiff’s complaint were not capable of defamatory
meaning, the court reached the correct result. To determine whether plaintiff abused his authority,
the trial court would have had to determine whether plaintiff was authorized to access the church’s
bank accounts under the employment agreement. That determination would impermissibly intrude
on matters of church organization and polity. Because “this Court does not reverse a lower court’s
decision where it reached the right result for a wrong reason,” we affirm the trial court’s decision.
Hawkins v Dep’t of Corrections, 219 Mich App 523, 528; 557 NW2d 138 (1996).
Affirmed.
/s/ Michelle M. Rick
/s/ Christopher M. Murray
/s/ Stephen L. Borrello

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