(dissenting). I respectfully dissent. Although I agree with the majority’s conclusion that the Free Exercise Clause of the First Amendment shields churches and their ministers from judicial review of any disciplinary practices involving members that do not pose a substantial threat to public safety, peace, or order, I depart from the majority in that I do not believe that any part of present plaintiff’s case hinges on whether plaintiff was a member of defendant church at the time of the disciplinary action in question. Because there is no dispute that the dissension between plaintiff and defendants arose from events that occurred while plaintiff was a member of the church, whether plaintiff was still a member at the time of defendants’ resulting disciplinary action, or had just resigned, or was in the process of being excommunicated, or was being “marked” (as *116Pastor Byers maintains) has no bearing on the resolution of this case.
The principle that a court must be vigilant in respecting the limits of its jurisdiction, see Straus v Governor, 230 Mich App 222, 227; 583 NW2d 520 (1998), lv gtd 458 Mich 865 (1998), applies especially where the controversy at hand implicates the Free Exercise Clause. All parties to this litigation and the majority concede that the central issue in this case is a dispute involving matters of religious doctrine, practice, and polity.1 Where the central issue involves a matter of religious doctrine or church discipline, civil courts may not assume jurisdiction over the controversy.2
“ ‘The civil courts will not enter into a consideration of church doctrine or church discipline, nor will they inquire into the regularity of the proceedings of the church judicatories having cognizance of such matters. To assume such jurisdiction would not only be an attempt by the civil courts to deal with matters of which they have no special knowledge, but it would be inconsistent with complete religious liberty untrammeled by State authority.’ ” [Berry v Bruce, 317 Mich 490, 501; 27 NW2d 67 (1947), quoting Borgman v Bultema, 213 Mich 684, 703; 182 NW 91 (1921), quoting *117Morris Street Baptist Church v Dart, 67 SC 338, 342; 45 SE 753 (1903).]3
The First Amendment provides ecclesiastical organizations with a shield covering all disciplinary practices involving their members that do not pose a substantial threat to public safety, peace, or order. Guinn v Church of Christ of Collinsville, 775 P2d 766, 779 (Okla, 1989). If church doctrine authorizes a sanction, the constitutional shield should remain in place even if the subject of the discipline has ceased to be a member, if the actions relate to church doctrine.4 Any other rule would involve the state in determining what is or is not a legitimate ecclesiastical disciplinary measure.5
In the present case, the parties and the majority agree that the dispute involves a matter of religious doctrine that arose while plaintiff was a member of the chinch. Because the dispute involves church doctrine, the disciplinary measure at issue is protected under the Free Exercise Clause of the First Amend-*118merit, even if it was imposed after plaintiff severed Ms membersMp in the church. WMle the majority cites Hadnot v Shaw, 826 P2d 978, 989 (Okla, 1992), for the proposition that a church loses its absolute privilege from tort liability concerning disciplinary actions after withdrawal or excommumcation of the disciplined person, I note that Hadnot also states that termination of that absolute privilege requires some “affirmative act” severing the affiliation of the subject of the discipline from the church. Id. Although in the present case plaintiffs precise status with defendants at the time of their disciplinary action against Mm is not clear, the record nowhere suggests that either plaintiff or defendants had affirmatively severed their religious ties. Further, Hadnot recognizes that a church retains the right to complete whatever processes against a former member that were in progress during that person’s period of membersMp.6 Id. at 987.
TMs Court, in Maciejewski v Breitenbeck, 162 Mich App 410; 413 NW2d 65 (1987), stated as follows:
It is well settled that courts, both federal and state, are severely circumscribed by the First and Fourteenth Amendments to the United States Constitution and art 1, § 4 of the Michigan Constitution of 1963 in resolution of disputes between a church and its members. Such jurisdiction is limited to property rights which can be resolved by application of civil law. Whenever the court must stray into questions *119of religious doctrine or ecclesiastical polity the court loses jurisdiction. [Id. at 413-414, citing Berry, supra; First Protestant Reformed Church v DeWolf, 344 Mich 624; 75 NW2d 19 (1956); Berkaw v Mayflower Congregational Church, 378 Mich 239; 144 NW2d 444 (1966); Bennison v Sharp, 121 Mich App 705; 329 NW2d 466 (1982); Beulah Missionary Baptist Church v Spann, 132 Mich App 118, 125; 346 NW2d 911 (1984) (H.R. Gage, J., concurring)].
For these reasons, I conclude that this Court has no jurisdiction to resolve this dispute.7 Accordingly, I would affirm the decision of the trial court in its entirety.
At issue is whether the church’s doctrine requires that its pastor keep confidential a member’s personal disclosures (a confession), or whether the pastor was within his rights under church law when he used information from plaintiff’s confession to announce to the congregation, including members of plaintiffs immediate family, that the membership should totally disregard plaintiff because he was of low moral character.
I also have some concern that once the majority renders its decision concerning church policy, and the trial court passes further on this on remand, defendant church may believe it is under court orders to adopt the judicial interpretations of its doctrine. Although I have little doubt that some religious dogma would benefit from interpretation according to modem conventions of civil jurisprudence, I have no doubt that this is precisely what our forefathers intended to avoid when drafting and ratifying the Free Exercise Clause of the First Amendment.
Although Berry and Borgman are admittedly old Supreme Court cases, they are still good law, and, unlike the sister-state cases on which the majority relies, binding on this Court.
If plaintiff was in fact no longer a member of the church at the time of defendants’ disciplinary measures, defendants’ postwithdrawal actions nonetheless remain conditionally privileged. See 3 Restatement Torts, 2d, §§ 593-594, pp 261-265.
Unfortunately, the majority diminishes the protections (shield) of the First Amendment by first drawing an artificial line (membership versus nonmembership), and then by concluding that the courts have the authority to review church policy and construe its doctrine as applied to the church’s expatriates. I am of the opinion that the elucidation of religious tenets is best left to theologians. Farther, while the majority cites two foreign-state cases in support of their current-member/former-member distinction regarding a church’s First Amendment right to impose ecclesiastical sanctions, I defer instead to binding precedent from this state’s Supreme Court. See n 3, supra.
I would liken this to a state’s continuing personal jurisdiction over a former citizen concerning matters arising while that person resided within the state. Just as one cannot evade a state’s jurisdiction over such matters simply by the expedient of taking up residence in another state, a parishioner should not be able to constrain continuing church practices stemming from and immediately following the parishioner’s affiliation simply by severing ties with the church.
In his brief on appeal, plaintiff states that he engaged the country's foremost expert in the interpretation of church doctrine, who is prepared to testify that it violates church doctrine for officials to reveal a member’s personal disclosures to the congregation: This expert may be correct, but I believe that the Free Exercise Clause of the First Amendment prohibits state courts from rendering judgments on such matters. While I mean no disrespect to plaintiff’s expert, theologians have been debating religious doctrine throughout the thousands of years of human history. It would be unfortunate to see this debate come to an end in any particular as a result of a state court’s judicial decision. Further, I think it neither wise nor proper for a state court to determine which among conflicting theologians has the superior knowledge concerning a religious controversy.