By Michael Gryboski, Editor Tuesday, September 16, 2025

An appeals court panel has ruled against Will McRaney, a former Southern Baptist state convention leader in his lawsuit accusing a missions agency of defamation.

McRaney had filed a lawsuit against the Southern Baptist Convention's North American Mission Board, claiming that it had gotten him fired from a position with the Baptist Convention of Maryland/Delaware.

However, a three-judge panel of the United States Court of Appeals for the Fifth Circuit ruled 2-1 last week to uphold a lower court dismissal of McRaney’s lawsuit against NAMB.

Circuit Judge Andrew S. Oldham authored the majority opinion, writing that NAMB was protected by “the church autonomy doctrine,” which “prohibits any court from adjudicating McRaney’s claims.”

“Civil courts cannot adjudicate ecclesiastical matters,” wrote Oldham. “The church autonomy doctrine also forbids courts from adjudicating matters of church governance, including church discipline and the church’s understanding of its own membership.”

“On the merits, the church autonomy doctrine bars all of McRaney’s claims against NAMB. Although his claims are facially secular, their resolution would require secular courts to opine on ‘matters of faith and doctrine’ and intrude on NAMB’s ‘internal management decisions that are essential to [its] central mission.’”

Circuit Judge Irma Carrillo Ramirez dissented from the majority, writing that McRaney’s “secular claims against a third-party organization do not implicate matters of church government or of faith and doctrine.”

“Determining whether NAMB acted ‘willfully or wantonly’ does not implicate religious beliefs, procedures, or law,” wrote Ramirez.

“Determining the veracity of these claims would not require any inquiry into Baptist religious beliefs, nor would it require assessing whether McRaney fulfilled his gospel calling. His defamation claim does not fail in its entirety.”

NAMB, which serves as the domestic missions agency for the SBC, was represented by the legal groups Wilmer Cutler Pickering Hale, the First Liberty Institute and Dorr LLP.

“We are grateful that the Fifth Circuit recognized this important principle of religious freedom,” said Matthew Martens, partner at Wilmer, in a statement released Monday.

“There should be no doubt that religious organizations and associations — not judges — have the freedom to choose how to fulfill their religious missions and with whom.”

In 2012, NAMB and the Baptist Convention of Maryland/Delaware entered into a Strategic Partnership Agreement centered on better evangelizing nonbelievers in the region.

McRaney, who was serving as executive director of the BCMD at the time, disagreed with NAMB over how to properly implement the SPA, with the missions agency taking issue with his leadership.

In June 2015, the board of the BCMD unanimously voted to terminate McRaney, reportedly due to issues with his leadership abilities. McRaney sued NAMB in 2017, claiming that the SBC entity had defamed him and influenced the 2015 decision to fire him.

In April 2019, a judge in Mississippi ruled against McRaney. However, a three-judge panel of the Fifth Circuit unanimously reversed the decision and remanded it to the lower court.

NAMB filed a petition with the United States Supreme Court in February 2021, arguing that it was protected by the ministerial exemption. The Supreme Court declined the petition.

In April of last year, a three-judge panel of the Fifth Circuit heard oral arguments in the case.