US court rules it cannot block Church of Nigeria’s restructuring of Indiana diocese

A superior court in Indiana, US, has given a verdict in favour of the Church of Nigeria and its senior clerics.

The court ruled that the dispute over the dissolution of the Anglican Diocese of the Trinity (ADOTT) is a purely ecclesiastical matter that civil courts cannot adjudicate.

ADOTT is a member of the Church of Nigeria North American Mission (CONNAM), a missionary initiative of the Church of Nigeria.

The legal conflict began in early 2024, when ADOTT sued the Church of Nigeria; Nathan Kanu, coordinating bishop of CONNAM; Henry C. Ndukuba, primate of the Church of Nigeria; CONNAM; Anglican Church of the Resurrection, Inc.; and Area One Great Lakes Missionary Region in the suit marked 49D01-2401-PL-003210.

ADOTT had asked the court to stop the Church of Nigeria from carrying out an unlawful dissolution of an Indiana-registered corporation. The diocese claimed the Church of Nigeria exceeded its authority and interfered with its corporate existence.

In February 2024, the court granted a temporary injunction, stopping the Church of Nigeria from taking further steps affecting ADOTT pending full consideration of the case.

THE JUDGMENT

In its final judgement, the Marion superior court found that the Church of Nigeria merely reorganised its operations in the US when it ceased using ADOTT and did not carry out any dissolution, as claimed by the plaintiff (ADOTT).

The court held that no church official took any step that qualifies as dissolution under Indiana law, and ADOTT’s corporate status was irrelevant to the church’s internal governance.

The court ruled that the plaintiff’s claims under Indiana dissolution law were baseless since there was no attempt—formal or otherwise—to dissolve the corporation.

Also, the court held that ADOTT’s claims against the Church of Nigeria and its leaders fall squarely under the First Amendment’s Church Autonomy Doctrine, which bars secular courts from resolving internal church governance disputes.

“The United States supreme court recently reaffirmed that while religious organisations can establish corporate entities, ‘religious institutions are a parallel authority to the state, not a creature of state law,’ and the state ‘may not use such entities as a means of regulating internal governance’; therefore, ADOTT’s status as an Indiana corporation does not give civil courts authority to settle ecclesiastical disputes,” the court held.

The court further held that ADOTT did not provide evidence of any property interest or any exception that would allow the court to intervene.

The order noted that the diocese’s founding documents “disclaim ownership of property”, that it is precluded from holding real estate, and that internal mechanisms exist for dispute resolution, all reinforcing the ecclesiastical nature of the case.

The ruling said ADOTT’s lawsuit “impermissibly seeks judicial control over church polity”, noting that the court is constitutionally barred from doing so.

As a result, the court granted summary judgement in favour of the defendants.

“There is no genuine dispute of material fact as to any claim asserted against the Movant Defendants,” the court ruled.

However, the court held that the claims against one defendant — Olukayode Adebogun (bishop of ADOTT) — remain unresolved.

The court struck out Adebogun’s filing to the extent that it purported to oppose the joint summary judgement motion, saying it was untimely and “not responsive”.

The judge gave the plaintiffs 60 days to state whether they intend to appeal or proceed with the case against Adebogun. If they choose to continue, they must request a status conference; otherwise, the court will move to close the matter administratively.