Alexander Belya was a priest in the Russian Orthodox Church Outside of Russia (“ROCOR”) and served at a parish in Miami. In 2018, church leadership considered Belya for elevation to bishop, but the parties sharply disputed what happened next. Belya maintained that ROCOR’s Metropolitan and other bishops told him he had been elected and provided him with letters documenting the election. Church leadership maintained that Belya had merely been considered as a candidate and had not satisfied certain prerequisites necessary for his candidacy to move forward, including bringing his parish’s property under the authority of the Diocese.
The dispute escalated in August 2019, when the Moscow Patriarchate publicly announced that it had approved Belya’s election as Bishop of Miami. ROCOR leadership asserted that the announcement came as a surprise because, according to the Church, Belya had never actually been elected. Church officials investigated and obtained three letters that had been sent to Moscow concerning Belya’s purported election. They identified a number of alleged irregularities in the letters, including that they described an election the officials maintained had never occurred and did not follow ROCOR’s procedures for communicating the election of a bishop (e.g., an official citation and a formal ecclesiastical biography of Belya).
Following the investigation, leaders of ROCOR’s Eastern American Diocese sent a letter to the Church’s Synod raising concerns about the purported election documents and accusing Belya of other misconduct. The letter requested that Belya be suspended and investigated further. He was suspended that same day and ultimately defrocked in February 2020. The letter was later posted on Facebook by a former parishioner, and other social media posts and Orthodox news articles repeated allegations that documents concerning Belya’s election had been forged.
Belya sued ROCOR entities and church leaders for defamation, principally contending that they falsely accused him of forging the letters. The trial court granted summary judgment to the defendants under New York defamation law and, independently, under the First Amendment’s church autonomy doctrine. The Second Circuit Court of Appeals affirmed solely on the church autonomy ground.
The Second Circuit explained that the church autonomy doctrine protects religious organizations’ independence in matters of faith and doctrine and closely related matters of internal governance. Although religious institutions do not have general immunity from secular law, courts cannot impose civil liability based on internal management decisions essential to a religious organization’s mission. Courts may still resolve disputes using neutral principles of secular law, but they must stop when adjudication would require excessive entanglement with religious doctrine or governance or require a factfinder to second-guess a religious organization’s understanding of its own affairs.
The Court concluded that this protection extends beyond the ultimate decision to hire, supervise, or terminate a minister. Religious leaders must also be able to communicate about who is qualified to serve in positions of religious importance without exposing those constitutionally protected decisions to collateral attack through tort claims. Thus, defamation claims based on communications made as part of a religious institution’s investigation, discipline, or termination of a minister may themselves be barred by church autonomy.
The Court found Belya’s claims protected on two related grounds. First, the allegedly defamatory letter resulted directly from church leaders’ investigation of Belya and served as a basis for the Church’s decision to discipline and ultimately remove him. Even assuming some statements in the letter were false and could theoretically be evaluated using secular evidence, permitting a jury to review the investigation would interfere with ROCOR’s constitutional authority to regulate the character and conduct of its religious leaders.
Second, the truth or falsity of the forgery accusation could not actually be resolved without examining ROCOR’s internal governance. Belya had evidence from a handwriting expert that the Metropolitan signed the disputed letters, and several church leaders acknowledged that the signatures appeared genuine. But ROCOR relied on evidence concerning its own procedures to support its position that the Metropolitan was not responsible for them, including who had authority to elect bishops, whether the required vote occurred, and whether the letters followed the Church’s protocols. A jury could not decide whose account was correct without deciding how ROCOR’s bishop-selection process operated and whether its internal procedures had been followed.
The Court reached the same result regarding the allegations later circulated on Facebook and in Orthodox media. Although those communications reached beyond ROCOR’s leadership, they repeated the findings of the Church’s protected investigation and remained intertwined with Belya’s purported election and removal. The Court held that, where an allegedly defamatory statement emerges from a religious institution’s protected investigation of a minister and implicates internal governance, church autonomy may bar the claim even when the statement is later repeated beyond the institution itself. The Court expressly left open how the doctrine might apply to communications directed primarily to secular audiences or claims capable of resolution entirely through neutral principles.
Belya v. Kapral (2d Cir. 2026) __F.4th__ [2026 WL 2408741].
Note: This decision is relevant for religious schools in that the church autonomy doctrine may protect not only a school’s ultimate decision concerning a ministerial employee, but also the investigation and internal communications underlying that decision in situations where adjudicating a claim would require a court to evaluate religious governance or second-guess the school’s understanding of its religious practices.