Key Cases
Free Exercise
Fired Pastor's Ousting During Church Service Did Not
Violate His Free Exercise Rights
Anthony J. Sirven
In Couzens v. City of Forest Park, Ohio, 114 F.4th
571, 574 (6th Cir. 2024), church leaders hired off-duty municipal
police officers to attend a service and help oust a pastor whom
members had voted to remove due to indiscretions. The pastor
refused to comply, whereupon the off-duty police officers went into
action. The pastor sued the city for allegedly violating his free
exercise rights. The district court dismissed the pastor's
claims on summary judgment, holding that the off-duty officers'
ousting of the pastor did not target "religious conduct."
The court of appeals agreed that the officers did not violate the
pastor's free exercise rights and explained, "The officers
attempted to enforce what, from their perspective appeared to be a
settled matter."
