But last
week, the 2nd U.S. Circuit Court of Appeals sided with the denomination, finding that the doctrine of church autonomy barred the court from interfering further in the conflict.
Religious rights experts lauded the ruling, which upheld the church’s ability to select, discipline, and remove its leaders.
“It’s reassuring. The court got it right,” said Carl
Esbeck, a religious rights professor at the University of Missouri’s law
school. “It’s a solid backing of church autonomy doctrine.”
In 2020, Belya sued the Russian Orthodox Church Outside of Russia
(ROCOR) after its officials suspended him pending an investigation. He
had previously worked as a priest overseeing a parish in Miami. ROCOR
has nearly 300 churches across the United States.
Belya contended that leaders told him during a 2018 meeting
that he was elected to a bishop role, provided he would correct some of
his ecclesiastical practices. He claims he received several letters
confirming his election, but church leaders say that at the same
meeting, they determined not to advance his role because of complaints
about his conduct.
In 2019, Belya traveled to the Moscow Patriarchate in
Russia, where he says that another leader submitted these letters to the
Patriarchate. Months later, the Patriarchate announced on its website
that it approved Belya’s election as a bishop in Miami.
ROCOR leaders contended that the Patriarchate’s affirmation caught them by surprise, as they said Belya had never been elected bishop. They alleged the letters the Patriarchate had received regarding Belya had numerous irregularities.
In an internal letter, they
discussed these irregularities and listed other alleged concerning
behaviors of Belya’s, such as using information from private confessions
to control his parishioners. The leaders called for an investigation
into Belya and urged for him to be suspended from his role as priest.
After the leaders’ internal letter was leaked in a
parishioner’s Facebook post, the dispute gained attention across
Orthodox media. A couple of Russian Orthodox leaders ultimately shared
links to articles discussing the claims against Belya, including the
suggestion that the letters submitted to the Patriarchate were
illegitimate.
ROCOR removed Belya as a priest in February 2020. The following August, he sued its leaders for defamation, claiming they damaged his reputation and standing within the ROCOR community by falsely accusing him of forgery.
He sought legal protection against having his character dragged through
the mud, according to Americans United for Separation of Church and
State, which represented Belya.
Belya argued that his lawsuit did not fall under the church
autonomy doctrine, which bars courts from interfering in internal
church decisions and governance. “Although this case involves religious
institutions and persons of the cloth, this is a straightforward
defamation action, the resolution of which entails no involvement
whatever in religious dogma or practice,” his lawsuit said.
But ROCOR argued that the case would require courts to
overstep their bounds by second-guessing the ministry’s internal
governance decisions. A district court in New York ruled in favor of
ROCOR. Belya appealed the decision to the 2nd Circuit in August 2025.
In last week’s decision, the 2nd Circuit upheld the lower
court’s opinion, stating that ROCOR’s selection and supervision of its
religious leaders are inherently religious acts that the First Amendment
protects.
“Evaluating the merits of Belya’s claims would
impermissibly require a jury to address numerous questions regarding
ROCOR’s governance and protocols for selecting its bishops,” a panel of
three judges wrote. A jury assessing the voting process of the ministry
would render the First Amendment’s protections of the church
meaningless, the panel said.
Even if the leaders’ internal documents contained false
statements, the documents were “squarely within the protection of the
church autonomy doctrine,” the appeals court said.
The court also extended these constitutional protections to
the leaders’ social media posts about Belya. While Belya had argued
these posts hurt his reputation, the court found that “church officials
must be free to engage in speech regarding their protected employment
decisions without fear of liability.”
WORLD reached out to Belya’s attorneys for comment but did not receive a response prior to publication.
A minister’s employment is intrinsically religious,
explained Esbeck, whether that employment decision involves a religious
issue—like doctrine—or a secular one—like gender or age.
Some defamation cases from church leaders can move forward
if they involve purely secular disputes, such as embezzlement claims,
said Douglas Laycock, a professor at the University of Virginia law
school, who co-authored a brief in support of ROCOR.
“The court might take that [kind of] case,” Laycock said.
“What you have to think about is if the make-up of the facts … really
don’t go to their religious position, or any kind of religious
question.” Laycock said he believed the 2nd Circuit got it right in this
“straightforward” case.
The 2nd Circuit’s ruling protects church leaders across
denominations, added Daniel Blomberg, an attorney at Becket Fund for
Religious Liberty, which represented ROCOR. Defamation cases have popped
up in a variety of denominations as an attempted workaround to the
church autonomy doctrine.
The 2nd Circuit also emphasized that religious leaders have
the right to conduct internal investigations and then communicate this
information to parishioners without court interference, said Blomberg.
“The members of a religious body need to know if there are concerns about the leadership. Religious communities are built on trust,” he said. “Churches need to be able to protect against shepherds who prey on their sheep.”