Circuit court rules against priest in Russian Orthodox Church bishop election dispute
A federal appeals court panel has ruled against a former Orthodox priest who claimed that denominational officials and others wrongfully blocked him from being made a bishop.
A three-judge panel of the 2nd U.S. Circuit Court of Appeals issued a unanimous ruling on Tuesday in the case of Alexander Belya v. Hilarion Kapral et al.
Belya sued individuals within the Russian Orthodox Church Outside of Russia (ROCOR), alleging that they wrongly accused him of forging letters announcing his election as bishop.
Circuit Judge Gerard Lynch, an Obama appointee, authored the panel opinion, writing that secular courts lacked constitutional authority to adjudicate the matter.
“Whatever the merits of Belya’s claims, their adjudication would impermissibly interfere with ROCOR’s selection and supervision of its ministers and would require a jury to determine the correct understanding of ROCOR’s own protocols and governance,” wrote Lynch.
Lynch cited the church autonomy doctrine, also called “the ecclesiastical abstention doctrine,” which bars courts from deciding any matters of doctrine or internal church governance.
Since the central focus of the litigation is how ROCOR selected its bishops, the circuit court found that this barred Belya’s claims.
“First, Belya’s claims interfere with ROCOR’s autonomy in selecting, supervising, and terminating its clergy,” wrote Lynch. “Second, 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.”
Diana Thomson, senior counsel at Becket, who, along with Donald J. Feerick Jr. and Alak Shah at Feerick Nugent MacCartney, PLLC, helped represent the church, celebrated the ruling.
“Churches can’t freely minister to the faithful if every internal leadership dispute can be the subject of a federal lawsuit,” Thomson said in a statement Tuesday.
“This ruling is a resounding victory for the principle that religious communities govern their own religious mission. It ensures that sacred decisions about who leads the faithful remain where they belong — inside the church, not a courthouse.”
In August 2020, Belya sued various ROCOR officials, claiming that he was wrongfully denied election as bishop, was defamed and even threatened over his efforts to be elevated.
U.S. District Judge Arun Subramanian ruled in favor of the ROCOR officials in March 2025, writing that Belya’s lawsuit suffered from two fundamental problems.
“First, putting aside the constitutional issues that dominate the parties’ briefing, Belya’s claims fail on routine state-law grounds,” wrote Subramanian.
“Second, even if Belya’s claims could otherwise proceed, a trial in this case would drag the Court and jury into matters of faith, spiritual doctrine, and internal church governance — precisely what the church-autonomy doctrine is designed to prevent.”
