Payne-Elliott v. Archdiocese of Indianapolis
In 2017 a high school teacher at Cathedral Catholic High School in Indianapolis violated his agreement with the school, and centuries of Church teaching, by entering a same-sex civil union. After two years of deliberation, the Archdiocese of Indianapolis informed the school that if it wanted to remain affiliated with the Catholic Church, it could not continue employing teachers who lived in defiance of Church teaching. The teacher then sued the Archdiocese in state court, arguing that the Archdiocese illegally interfered with his agreement.
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Commitment to Catholic education
The Archdiocese of Indianapolis has been committed to teaching the Catholic faith and serving central and southern Indiana for over 175 years. In addition to providing tens of millions of dollars in vital social services, the Archdiocese operates a number of schools that provide a safe, high-quality education to thousands of low-income Indiana students.
The purpose of these schools is not only to provide a top-notch education, but to transmit the Catholic faith to the next generation. Thus, it is of particular importance that educators in Catholic schools respect and promote the Church’s teachings. This is why, when they are hired, all educators in the Archdiocese sign an agreement to uphold the teachings of the Catholic Church in both their professional and private lives—serving as examples of the faith to both the students and the community alike.
A broken agreement
In 2017, Joshua Payne-Elliott, a teacher at Cathedral Catholic High School, entered a same-sex civil union in violation of his employment agreement and centuries of Catholic teaching. For almost two years, the Archdiocese engaged in discussion with Cathedral High School about the best course of action based on Catholic teaching. In the end, the Archdiocese informed Cathedral that if it wanted to remain affiliated with the Catholic Church, it could not continue employing teachers who lived in defiance of Church teaching.
Wishing to remain a Catholic school, Cathedral separated from Mr. Payne-Elliott. Mr. Payne-Elliott then sued the Archdiocese in state court, arguing that it unfairly interfered in his agreement with the school.
Defending church autonomy
The Supreme Court has long recognized that secular courts have no business interfering in matters of church discipline or internal church governance. As the Indiana Supreme Court put it a century ago, “No power save that of the church can rightfully declare who is a Catholic.” Accordingly, Becket is defending the Archdiocese, arguing that the government cannot punish the Archdiocese for telling a Catholic school what rules it needed to follow in order to remain a Catholic school.
On May 7, 2021, the Marion Superior Court of Indiana agreed and dismissed the case, ruling in favor of the Archdiocese. The Indiana Court of Appeals, however, reversed, permitting the lawsuit to proceed. Becket then asked the Indiana Supreme Court to step in.
On August 31, 2022, the Indiana Supreme Court unanimously protected the Archdiocese, explaining that the “Constitution encompasses the right of religious institutions to decide for themselves, free from state interference, matters of church government.” The decision protects the Archdiocese’s freedom to ensure students and families receive an authentic Catholic education.
Importance to Religious Liberty:
- Religious Communities—Churches and religious organizations have a right to live, teach, and govern in accordance with the tenets of their faith. When the government unjustly interferes in internal church affairs, the separation of church and state is threatened. The First Amendment ensures a church’s right to self-definition and free association.