Taylor v. Evangelical Covenant Church

Circuit court dismissed plaintiff’s complaint pursuant to 735 ILCS 5/2-615 finding that his claims were barred by both the ecclesiastical abstention doctrine and the ministerial exception. The appellate court affirmed finding that the first amendment barred secular adjudication of plaintiff’s claims because any judgment by the court would require the determination of whether a religious institution’s investigations into sexual assault allegations were timely and fair. (MCBRIDE and ELLIS, concurring.)