United States Ninth Circuit

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Puri v. Khalsa, 13-36024

In a dispute over the control of two nonprofit entities associated with the Sikh Dharma religious community, the district court's dismissal of the claims, as foreclosed by the Free Exercise and Establishment Clauses of the First Amendment, is vacated where: 1) based only on the pleadings, the claims were not barred by the First Amendment's ministerial exception; and 2) the ecclesiastical abstention doctrine did not apply because the claims could be resolved by application of neutral principles of law without encroaching on religious organizations' right of autonomy in matters of religious doctrine and administration.

Appellate Information

  • Decided
  • Published 2017/01/06




  • United States Ninth Circuit