COA 371185 RUMMAN AHMED V AMERICAN MUSLIM DIVERSITY ASSOCIATION Opinion - Per Curiam - Unpublished 9/11/2026

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
RUMMAN AHMED,
Plaintiff-Appellant,
UNPUBLISHED
September 11, 2026
1:17 PM
v No. 371185
Macomb Circuit Court
AMERICAN MUSLIM DIVERSITY
ASSOCIATION, also known as AMDA,
MUHAMMAD AZIM, MARINA AZIM, FERDOUS
GHAZI, JAVID KHATRI, SARIA SADIQUE, and
AHMED KHAN,
LC No. 2023-002457-CB
Defendants-Appellees.
Before: LETICA, P.J., and RICK and GARRETT, JJ.
PER CURIAM.
Plaintiff, Rumman Ahmed, worked as an assistant Imam—a religious leader—for
defendant American Muslim Diversity Association (AMDA). After two individuals alleged that
Ahmed committed domestic violence against them, AMDA’s board of trustees terminated
Ahmed’s contractual relationship with AMDA. Ahmed filed suit, alleging breach of contract,
defamation, false-light invasion of privacy, intentional infliction of emotional distress, and concert
of action. Ahmed appeals by right the trial court’s order granting defendants’ motion for summary
disposition on the basis that the ecclesiastical abstention doctrine precluded the court from
analyzing Ahmed’s claims. Because the trial court correctly determined that the ecclesiastical
abstention doctrine barred Ahmed’s claims, we affirm.
I. FACTUAL BACKGROUND
AMDA is a Mosque located in Sterling Heights, Michigan. From 2009 until 2022, Ahmed
worked as an assistant Imam in the Mosque and the associated school. Ahmed worked for AMDA
pursuant to an independent-contractor agreement, which AMDA renewed every year with the most
recent renewal occurring on January 8, 2022, for the 2022 year. The individual defendants are
members of AMDA’s board of trustees, board of representatives, or both. According to Ahmed,
beginning in 2021 the individual defendants engaged in a “smear campaign” against him by falsely

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accusing him of lying while performing his duties as a religious leader and refusing to lead certain
prayers. He also alleged that defendants disparaged his character by discussing his recent divorce
and the allegations of domestic violence that had been made against him.
Both Ahmed’s sister and ex-wife accused Ahmed of domestic violence. An October 2020
Hamtramck police report indicated that Ahmed’s sister accused him of smashing a glass object
next to her head and threatening to kill her. The report stated that Ahmed grabbed her phone away
from her when she tried to call the police, but she was able to call the police after she left Ahmed’s
residence, where the incident occurred. Although police officers arrested Ahmed, his sister
declined to pursue charges against him the next day. A July 2021 Hamtramck police report
indicated that a good Samaritan transported Ahmed’s then-wife to the police station after she was
observed crying on the sidewalk outside her home. She arrived in the lobby of the police station
shortly after 10:00 p.m. and informed officers that Ahmed had a history of abusive conduct with
her. She reported that she was attempting to clean up a spilled beverage that night when Ahmed
asked her why she was acting like a dog, struck her twice on the left side of her face, and struck
her once on the right side of her face. EMS arrived and treated her injuries, but she declined to be
transported to the hospital.
At an April 9, 2022 special AMDA joint meeting,1 defendants discussed the domestic-
violence allegations, including Ahmed’s denial of the allegations and insistence that his ex-wife
had lied. The joint committee concluded that it was unable to verify the allegations after hearing
“the evidence and the statements from both sides” and was unable to reach a unanimous
determination about whether the allegations were true. The committee nevertheless determined
that “it would be better for AMDA and would be the single best thing” for Ahmed to work
elsewhere. It was agreed that “an amicable discussion” would be had with Ahmed regarding
releasing him from his duties after May 31, 2022. Ahmed maintains that, thereafter, AMDA
refused to allow him to speak at an April 16, 2022 Ramadan fundraising event he was scheduled
to speak at and refused to allow him to lead certain prayers.
In June 2022, AMDA’s board of trustees issued a report concerning its investigation of the
domestic-violence allegations against Ahmed. Consistent with its finding at the April 9, 2022
special AMDA joint meeting, the report stated the allegations “could not be proved as credible.”
Ahmed was not advised of AMDA’s decision to release him from his duties before the July 16,
2022 AMDA joint meeting was held. At that meeting, it was determined that Ahmed would be
relieved of his duties after August 31, 2022. The participants also voted to give Ahmed four
months’ severance pay and to require him to sign a document indicating that AMDA was immune
from liability before the compensation was payable. AMDA sent Ahmed a termination letter and
a settlement letter stating it would pay Ahmed a single, lump-sum payment of $11,200 if he signed
AMDA’s proposed settlement agreement. Ahmed did not sign the agreement and did not receive
severance pay.
Thereafter, Ahmed filed a complaint against defendants alleging that they falsely told
members of the Muslim community he was terminated from his position because he was not
1 It appears from the record that the joint meeting was a meeting attended by members of the board
of trustees and board of representatives.

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qualified to be a religious leader at the Mosque, he was not competent to perform his job
responsibilities, and he was not educated enough, which implied he did not have a high school
diploma. He maintained that defendants’ “defamation campaign” against him to the broader
Muslim community was ongoing, and his dentist interrogated him about his qualifications as an
Imam after hearing he was terminated because of his lack of education. He further alleged that he
was unable to find employment as an Imam in the Muslim community because of defendants’
defamation. He asserted claims alleging breach of contract (Count I), defamation (Count II), false-
light invasion of privacy (Count III), intentional infliction of emotional distress (Count IV), and
concert of action (Count V).
Defendants moved for summary disposition under MCR 2.116(C)(8) and (10). Relevant
to this appeal, defendants argued the ecclesiastical abstention doctrine, which requires deference
to a religious entity’s decisions in ecclesiastical matters, compelled the dismissal of Ahmed’s
claims. They asserted that adjudication of Ahmed’s claims necessarily involved inquiring into
AMDA’s investigation and resolution of the allegations against Ahmed as well as AMDA’s
method of evaluating the allegations, which the First Amendment prohibits. Moreover, defendants
argued that Ahmed’s relationship with AMDA was at-will, and the independent-contractor
agreement stated that either party could terminate the agreement at any time by providing written
notice.
Ahmed opposed the motion, arguing it was premature because discovery was ongoing, and
the ecclesiastical abstention doctrine did not preclude courts from resolving disputes based on a
contract, such as the instant case. Ahmed asserted that defendants still had not provided a reason
for his termination, and they conducted an extensive investigation into the allegations against him,
ultimately concluding the allegations could not be proven credible. Ahmed maintained that his
contract with AMDA specifically stated AMDA could take action only based on the outcome of
its investigation, but AMDA nevertheless terminated the contract and breached it in doing so
because the contract did not permit AMDA to terminate the contract without cause. He asserted
that although a court cannot substitute its opinion for that of a religious tribunal in ecclesiastical
matters, this case is a contract dispute rather than a religious one, and the ecclesiastical abstention
doctrine did not preclude the court’s ability to adjudicate the dispute.
The trial court granted defendants’ motion. First addressing Ahmed’s breach-of-contract
claim, the court determined that resolving the claim “would require delving into the Board of
Trustees’ investigation and deliberations as well as the procedure it used when determining to
terminate” the independent-contractor agreement. The court opined that the First Amendment
prohibited such inquiries. Regarding Ahmed’s tort claims, the court found Perrone v Bugarin,
unpublished per curiam opinion of the Court of Appeals, issued December 21, 2021 (Docket No.
356201), persuasive despite being unpublished. The court stated:
Consistent with Perrone, adjudicating Plaintiff’s tort claims would require
this Court to inquire into the investigatory and decision-making process of
AMDA’s leadership for domestic violence allegations and for choosing and
evaluating its leaders and teachers. It would also require the Court to evaluate the
method AMDA’s leadership communicated with AMDA’s members. All these
matters are quintessentially ecclesiastical and the Court’s intrusion into them is
barred by the First Amendment.

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Further, the court did not find Perrone distinguishable on the basis that it did not involve a contract.
The court stated that Ahmed failed to cite caselaw indicating that “a court may interfere in a
religious organization’s decision over who may serve as its spiritual leader simply because there
is an employment contract,” and “[t]o the contrary, federal and state courts have established a near-
bright-line rule that the government, including the courts, cannot dictate to a religious organization
who its spiritual leader will be.” Finding that all Ahmed’s claims required the court to resolve
ecclesiastical questions, the court determined that the ecclesiastical abstention doctrine barred the
claims and granted defendants’ motion for summary disposition. This appeal followed.
II. ANALYSIS
We review de novo a trial court’s decision on a motion for summary disposition. Houston
v Mint Group, LLC, 335 Mich App 545, 557; 968 NW2d 9 (2021). Defendants moved for
summary disposition under MCR 2.116(C)(8) and (C)(10). It appears that the trial court granted
the motion under subrule (C)(8) on the basis that Ahmed failed to state a claim upon which relief
could be granted. See MCR 2.116(C)(8). A motion under subrule (C)(8) is decided based on the
pleadings alone. Laurel Woods Apartments v Roumayah, 274 Mich App 631, 635; 734 NW2d 217
(2007). The trial court referenced the language of the independent-contractor agreement during
oral argument, but it does not appear that the court relied on any other documentary evidence in
deciding the motion. If a claim is based on a contract, the plaintiff must attach a copy of the
contract to the complaint, and it “becomes part of the pleadings themselves, even for purposes of
review under MCR 2.116(C)(8).” Id. Summary disposition under subrule (C)(8) “should be
granted only when the claim is so clearly unenforceable as a matter of law that no factual
development could possibly justify a right of recovery.” MacDonald v PKT, Inc, 464 Mich 322,
332; 628 NW2d 33 (2001).
“The ecclesiastical abstention doctrine arises from the Religion Clauses of the First
Amendment of the United States Constitution[.]” Winkler v Marist Fathers of Detroit, 500 Mich
327, 337; 901 NW2d 566 (2017). The First Amendment states, “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 ecclesiastical
abstention doctrine reflects the
longstanding recognition 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. [Winkler, 500 Mich at 337-338 (quotation marks and
citation omitted).]
In accordance with the ecclesiastical abstention doctrine, a court “may not substitute its
opinion in lieu of that of the authorized tribunals of the church in ecclesiastical matters.” First
Protestant Reformed Church of Grand Rapids v DeWolf, 344 Mich 624, 631; 75 NW2d 19 (1956).
“[A]pplication of the ecclesiastical abstention doctrine is not determined by reference to the

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category or class of case the plaintiff has stated.” Winkler, 500 Mich at 341. “Whether a claim
sounds in property, tort, or tax, for instance, is not dispositive.” Id. “What matters instead is
whether the actual adjudication of a particular legal claim would require the resolution of
ecclesiastical questions; if so, 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.
Notably, the ecclesiastical abstention doctrine does not divest a court of jurisdiction to hear matters
involving ecclesiastical questions; instead, in exercising its jurisdiction, a court must resolve “the
matter consistent with any determinations already made by the religious entity.” Id. at 340
(quotation marks and citation omitted).
Ahmed’s breach-of-contract claim alleged that AMDA violated the independent-contractor
agreement by terminating it without just cause, which Ahmed asserts was required to terminate
the contract. The contract stated as follows:
If any allegation of violation of contractual agreements [sic], any activities against
principles of Islam, or any activity subversive to the mission and objective of
AMDA is raised against the Qa’ari Imam, the Board of Trustees will immediately
initiate an investigation. The Qa’ari Imam will be subjected to the due process and
will have opportunity to defend. Action will only be taken based on the outcome
of the investigation and the due process.
The Board of Trustee[s] shall reserve the right to cancel this contract at any time
with a written notice, if there are any violation [sic] in contractual agreement, any
activities against principles of Islam, or any activity subversive to the mission and
objective of AMDA by the Qa’ari Imam as determined by the Board of Trustees.
* * *
This contract can be cancelled at any time by either party provided a written notice
is served with an effective date.
Ahmed alleged in his complaint, and argues in his brief on appeal, that he never violated the
contract, and the board of trustees did not determine that he violated the contract after its
investigation. He asserts that the contract could not be terminated without cause.
Initially, we note that Ahmed asserted in his appellate brief that the contract contains
specific language that it does not. Ahmed argued:
Plaintiff’s 2021 contract with the Defendant AMDA states, in pertinent part:
“ . . . The Board’s right to cancel an Imam’s contract is NOT a severable provision,
and the contract DOES NOT allow AMDA to cancel an Imam’s contract without
cause.” (See Exhibit 5, 2021 AMDA Contract).
As Ahmed acknowledged during oral argument, the independent-contractor agreement contains
no such language. In any event, even if the contract could be terminated only with cause, Ahmed’s
argument is unavailing.

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The trial court correctly determined that resolution of Ahmed’s breach-of-contract claim
would require the court to delve into ecclesiastical matters. The contract stated that the board of
trustees reserved the right to cancel the contract “if there are any violation [sic] in contractual
agreement, any activities against principles of Islam, or any activity subversive to the mission and
objective of AMDA by the Qa’ari Imam as determined by the Board of Trustees.” Although the
board of trustees determined the domestic-violence allegations could not be substantiated, it may
have also determined that Ahmed violated the contract or engaged in activity contrary to the
principles of Islam or subversive to AMDA’s mission and objective. The ecclesiastical abstention
doctrine precluded the trial court from examining and second-guessing the decision of the board
of trustees that it would be best for AMDA if Ahmed no longer served as an assistant Imam. “Civil
courts will not enter into a consideration of church doctrine or church discipline nor will they
inquire into the regularity of the proceedings of church tribunals having cognizance of such
matters, since to do so would be inconsistent with complete and untrammeled religious liberty.”
First Protestant Reformed Church, 344 Mich at 632 (quotation marks and citation omitted). In
accordance with the ecclesiastical abstention doctrine, the trial court properly resolved Ahmed’s
breach-of-contract claim consistent with the determination of AMDA’s board of trustees. See
Winkler, 500 Mich at 340.
Ahmed also argues that the trial court erred by determining that resolution of his tort claims
would require analyzing questions involving religious doctrine and ecclesiastical polity. In his
complaint, Ahmed alleged that defendants made statements and falsely portrayed him as an
individual who lacked the education and character necessary to perform his duties as an assistant
Imam and created the false impression that he engaged in criminal wrongdoing and did not follow
religious teachings. He further alleged that defendants’ conduct was extreme and outrageous.
To establish a defamation claim, a plaintiff must prove:
(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. [Edwards v Detroit News, Inc, 322 Mich App 1, 12; 910 NW2d 394
(2017) (citation omitted).]
“In order to maintain an action for false-light invasion of privacy, a plaintiff must show that the
defendant broadcast to the public in general, or to a large number of people, information that was
unreasonable and highly objectionable by attributing to the plaintiff characteristics, conduct, or
beliefs that were false and placed the plaintiff in a false position.” Puetz v Spectrum Health Hosps,
324 Mich App 51, 69; 919 NW2d 439 (2018) (quotation marks and citation omitted). Intentional
infliction of emotional distress requires a plaintiff to prove: “(1) extreme and outrageous conduct,
(2) intent or recklessness, (3) causation, and (4) severe emotional distress.” Swain v Morse, 332
Mich App 510, 534; 957 NW2d 396 (2020) (quotation marks and citation omitted). Finally, “to
establish a concert-of-action claim, a plaintiff must prove that all defendants acted tortiously
pursuant to a common design that caused harm to the plaintiff.” Urbain v Beierling, 301 Mich
App 114, 132; 835 NW2d 455 (2013) (quotation marks and citation omitted).

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In ruling on defendants’ motion with respect to Ahmed’s tort claims, the trial court relied
on Perrone.2 In that case, the plaintiff priest was removed from a parish because of sexual abuse
allegations made against him. Perrone, unpub op at 1. The defendant announced the reason for
the plaintiff’s removal to the parish, stating that credible sexual abuse allegations had been made
against the plaintiff. Id. at 1-2. The plaintiff filed suit, alleging defamation, intentional infliction
of emotional distress, and false-light invasion of privacy. The defendant moved for summary
disposition, asserting that the ecclesiastical abstention doctrine precluded the trial court from
analyzing the plaintiff’s claims. The trial court agreed and granted the motion. Id. at 2. On appeal,
the plaintiff argued that the trial court was not required to determine matters involving church
policy or doctrine to adjudicate his claims. Id. at 3. This Court disagreed, stating that whether the
plaintiff could prove the falsity of the defendant’s statement to the parish “turn[ed] on the manner
in which the Archdiocese investigates and evaluates claims of sexual abuse made against its
clergy.” This Court also opined that analyzing the plaintiff’s intentional infliction of emotional
distress and false-light invasion of privacy claims required examining how the Archdiocese
evaluated the sexual abuse allegation and the method by which the Archdiocese communicated
with its parish. This Court thus upheld the trial court’s determination that the ecclesiastical
abstention doctrine barred the plaintiff’s claims. Id. at 4.
In the instant case, analyzing Ahmed’s defamation and false-light invasion of privacy
claims would require determining the truth or falsity of defendants’ alleged statements calling into
question whether Ahmed was qualified to perform the duties of an assistant Imam. Ahmed alleged
that defendants falsely stated he was not so qualified and lacked the character required and
expected of an assistant Imam. As in Perrone, this Court will not second-guess a religious entity’s
investigation and evaluation of allegations involving its leaders or its method of communicating
matters relevant to such allegations. Because Ahmed’s intentional infliction of emotional distress
and concert of action claims also involve evaluating defendants’ decisions and method of reaching
their decisions, those claims fail for the same reasons. Accordingly, the trial court did not err by
granting defendants’ motion for summary disposition with respect to Ahmed’s tort claims.
Affirmed.
/s/ Anica Letica
/s/ Michelle M. Rick
/s/ Kristina Robinson Garrett
2 Although unpublished decisions of this Court are not precedentially binding, MCR 7.215(C)(1),
they may be instructive and persuasive. Paris Meadows, LLC v City of Kentwood, 287 Mich App
136, 145 n 3; 783 NW2d 133 (2010).

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