US Court Rules It Lacks Power To Stop Church Of Nigeria’s Indiana Restructuring

A superior court in Indiana has ruled that it has no authority to block the Church of Nigeria’s restructuring of its Indiana-based diocese.

Gatekeepers News reports that the court said that the dispute is an internal church matter outside civil court jurisdiction.

The legal battle began when the Anglican Diocese of the Trinity (ADOTT), a unit under Church of Nigeria North American Mission (CONNAM), filed a lawsuit in early 2024 against Church of Nigeria; CONNAM; coordinating bishop Nathan Kanu; primate Henry C. Ndukuba; Anglican Church of the Resurrection, Inc.; and Area One Great Lakes Missionary Region.

ADOTT alleged that the Church of Nigeria attempted an unlawful dissolution of an Indiana-registered corporation and interfered with its corporate existence.

A temporary injunction was issued in February 2024 to prevent the Church of Nigeria from taking further steps until the matter received full judicial review.

In its final judgment, the Marion superior court determined that the Church of Nigeria had merely reorganised its operations in the United States by discontinuing the use of ADOTT and had not dissolved the body as alleged.

The court found that no action taken by church officials met the legal threshold for dissolution under Indiana law, adding that the diocese’s corporate status had no relevance to decisions concerning internal church governance.

The ruling emphasised that the claims brought under Indiana’s dissolution laws were without merit because there was no attempt either formal or otherwise to dissolve the corporation.

The court concluded that ADOTT’s arguments were entirely governed by the First Amendment’s Church Autonomy Doctrine, which prevents civil courts from intervening in internal religious governance.

Referring to a recent US Supreme Court position, the ruling highlighted that religious institutions are a parallel authority to the state, not a creature of state law, and the state may not use such entities as a means of regulating internal governance.

The court therefore held that ADOTT’s Indiana corporate registration did not grant civil jurisdiction over the dispute. ADOTT, according to the judgment, failed to establish any property interest or legal exception that could justify court intervention.

The diocese’s founding documents were noted to disclaim ownership of property, bar it from holding real estate, and include internal avenues for resolving disputes, all reinforcing the ecclesiastical character of the disagreement.

The ruling described the lawsuit as one that impermissibly seeks judicial control over church polity, a step barred by constitutional protections.

The court subsequently granted summary judgment in favour of the defendants, concluding that there is no genuine dispute of material fact as to any claim asserted against the Movant Defendants.

It One exception remains: claims against Olukayode Adebogun, bishop of ADOTT, have not been resolved. His filing opposing the joint summary judgment motion was struck out for being untimely and “not responsive”.

The plaintiffs have been given 60 days to indicate whether they intend to appeal or continue the case against Adebogun. If they decide to proceed, they must request a status conference; if not, the court will close the matter administratively.

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