A federal judge has dismissed a proposed class-action lawsuit accusing Gateway Church and its founding pastor, Robert Morris, of financial fraud involving church tithes. The suit had sought more than $100 million in damages and a jury trial.
Judge’s Ruling U.S. District Judge Amos L. Mazzant ruled that the ecclesiastical abstention doctrine bars civil courts from intervening in internal church matters. The doctrine protects religious institutions’ autonomy under the First Amendment.
The judge determined that evaluating whether the church properly used plaintiffs’ tithes would require the court to adjudicate ecclesiastical (religious) decisions. He relied heavily on a recent expanded opinion in the case McRaney v. North American Mission Board (Southern Baptist Convention), which strengthened the application of this doctrine.
Mazzant quoted defense arguments that the claims “would intrude upon Gateway’s religious freedom and autonomy… and are therefore barred by the First Amendment.” Although he had previously suggested the doctrine might not block the case, the updated precedent made dismissal “inescapable.”
Background on Robert Morris and Gateway Church Robert Morris founded Gateway Church in Southlake, Texas. He resigned in June 2024 after Cindy Clemishire publicly alleged that Morris sexually abused her in the 1980s, beginning when she was 12 years old and he was in his 20s.
Morris had previously admitted to “inappropriate sexual behavior with a young lady” but did not disclose that she was a minor. An independent investigation later revealed that former church elders and staff knew Clemishire was underage years earlier.
In October 2025, Morris pleaded guilty in Oklahoma to five felony counts of child sex abuse. He was sentenced to 10 years in prison, with all but six months suspended. He was released on March 31, 2026, and must register as a lifetime sex offender. He was also ordered to pay Clemishire $270,000 in restitution.
The tithing lawsuit dismissal highlights ongoing legal protections for churches regarding internal financial and doctrinal decisions, even amid significant leadership scandals.
Morris and Gateway recently resolved a dispute over retirement benefits Morris claimed were due him. Clemishire is seeking over $1 million in a defamation lawsuit against Morris, Morris’ wife, and other Gateway leaders.
In October 2024, four people who had donated to Gateway Church filed a lawsuit against the church, Robert Morris, Thomas M. Lane, Kevin L. Grove, and Steve Dulin. The plaintiffs were Katherine and Garry Leach and Mark and Terri Browder “on behalf of themselves and those similarly situated.” A second amended complaint filed in October 2025 lists only the church, Morris, and Dulin as defendants.
In their original complaint, the plaintiffs said that Gateway Church and its leaders claimed that 15% of tithe dollars would go to global missions and Jewish ministries and also promised to issue dissatisfied donors refunds. However, plaintiffs alleged that the church diverted some funds elsewhere and refused to return donations.
“Plaintiffs seek transparency and an explanation of what happened to the 15% of funds collected that Robert Morris, Tom Lane, and the other named Defendants promised would be used for global missions,” the plaintiffs said. “If it turns out that Defendants have not used the money as represented, as is suggested by credible allegations, then the purpose behind this lawsuit is to return the money to the tithers so that they may give as originally intended.”
The plaintiffs said that church leaders had promised to return donations “if the congregation is not happy with the use of its money,” but the plaintiffs alleged that “many people have requested a refund of their tithes only to be stonewalled and ignored by the Defendants at first.”
In their second amended complaint, the plaintiffs repeated their fraud allegations and added a civil RICO claim, alleging that Gateway and its leaders used mail and interstate wire communications to further a scheme to solicit donations through false representations.
Judge Amos L. Mazzant dismissed the case against Gateway Church, Robert Morris, and Steve Dulin on June 23. In his opinion explaining his reasons for doing so, Mazzant noted that on Sept. 17, 2025, he had chosen not to dismiss the case based on the ecclesiastical abstention doctrine because “at that point, the claims in Plaintiffs’ first amended complaint implicated non-religious conduct.”
At that time, the judge deemed the lawsuit to be dealing with civil, not religious, matters. After the second amended complaint repeated the plaintiffs’ initial claims and added the alleged RICO violation, Mazzant said he took the defendants’ motion to dismiss as a chance to reevaluate whether or not the ecclesiastical abstention doctrine was relevant.
The judge cited a number of other cases in his reasoning but especially noted the ruling in the case of McRaney v. the North American Mission Board. He noted that the first opinion in the NAMB case was issued Sept. 9 (days before his decision allowing the Gateway case to continue) and that a second NAMB opinion was issued on Oct. 28.
In McRaney v. the North American Mission Board, former Baptist state convention executive Will McRaney sued NAMB, alleging that the organization interfered with his employment and damaged his reputation after a dispute over ministry partnerships and governance.
The Fifth Circuit U.S. Court of Appeals ultimately dismissed McRaney’s claims, holding that the First Amendment’s church autonomy doctrine bars civil courts from adjudicating disputes that would require them to intrude into internal church governance, ministry relationships, or other ecclesiastical matters.
On Oct. 28, the Fifth Circuit withdrew its earlier September opinion in the case and issued a substituted opinion, which did not change the ruling but did more broadly define the scope of the church autonomy doctrine. The revised opinion emphasized that the doctrine functions as a constitutional immunity from suit and bars civil courts from adjudicating disputes involving ecclesiastical matters.
Mazzant referred to the McRaney/NAMB case multiple times in his opinion. “The Court agrees that McRaney must inform its analysis this time around,” he said. “McRaney is binding on the Court and the Fifth Circuit has put it simply: ‘[c]ivil courts cannot adjudicate ecclesiastical matters.’”
The judge pointed out that the plaintiffs did not claim “that Morris, Dulin, or any other Gateway leader pocketed their tithe dollars for personal gain.”
“Indeed,” said Mazzant, “Plaintiffs have alleged that Defendants diverted their donations to ‘secret organizations,’ which Plaintiffs have not defined, and that Defendants maintain that the donated funds were ‘used for the church’s many charitable purposes.’”
Mazzant said that, if the plaintiffs had alleged that Gateway leaders had used money for personal gain, his analysis might have been different.
ChurchLeaders reached out for comment to attorneys for the plaintiffs as well as to Katherine Leach and received no reply at the time of publishing this article. However, in a Facebook post, Leach called the case’s dismissal “a stark reminder of the incredible lengths to which institutionally shielded organizations will go, and spend, to keep their financial statements in the dark.”
“By invoking the Ecclesiastical Abstention Doctrine as a shield, Gateway and its leadership used a First Amendment loophole to keep the books completely hidden,” she said.
“When Pastors, Elder Boards, and CPAs preach ‘honesty and transparency’ and insist ‘independently audited financial statements’ exist while aggressively shielding themselves from having to publicly show their receipts, the silence speaks volumes,” said Leach. “True integrity doesn’t hide behind abusive NDAs—or manipulate our beloved Constitution to shield financial corruption.”
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Leach noted that the judge said that the court may not investigate the plaintiffs’ claims, not that the defendants were innocent. She said that attorneys were “actively reviewing” the decision and that she would give “an update as soon as more information becomes available.”
ChurchLeaders also reached out for comment to Gateway Church and to Robert Morris.
Ronald Breaux, counsel to Gateway, said, “We are grateful that the United States District Court has dismissed all claims against Gateway.”
“Plaintiffs sought to second-guess Gateway’s beliefs and decisions on the fundamental religious question of tithing. The First Amendment prohibits such an assault on Gateway’s religious autonomy and freedom,” said Breaux. “The District Court rightly recognized that resolving the Plaintiffs’ claims would require the Court to conduct an inquiry into matters that are essential to Gateway’s central mission, and it properly dismissed Plaintiffs’ claims.”
In his own statement, Robert Morris said, “First, I am grateful for the Court’s thoughtful consideration of this case and its decision to dismiss it.”
“Second,” he said, “I want to be absolutely clear that during my 24 years as Senior Pastor of Gateway Church, tithe monies were faithfully and properly stewarded, and not one dollar was misdirected – not by me, and not by Gateway.”
“Every gift entrusted to us was used to advance the mission God called us to, including our global missions work and our support of Jewish ministry partners, and directed toward the many other charitable purposes to which Gateway was committed,” said Morris. “Finally, let me thank the many friends, family members, and Gateway family who have prayed and stood with us throughout this entire process; your faithfulness has meant more to me than words can express.”
