A federal judge in Texas dismissed a class-action RICO lawsuit against Gateway Church and its founder Robert Morris on Tuesday, ruling that the First Amendment bars civil courts from second-guessing how a church spends its donated funds. The decision, handed down by U.S. District Judge Amos L. Mazzant in the Eastern District of Texas, Sherman Division, closed a case that had accused the Southlake megachurch and its former leaders of misusing millions of dollars in tithes and offerings.

The ruling turns on a legal principle that conservative legal observers have long defended, and that progressive critics call a loophole. The ecclesiastical abstention doctrine holds that courts may not wade into the internal management decisions of religious organizations when doing so would require judges to interpret matters of faith, doctrine, or church governance. Judge Mazzant concluded that this is exactly what the plaintiffs were asking him to do.

For the former church members who brought the suit, the decision is a bitter setback. For churches and religious liberty advocates, it reaffirms a boundary the Fifth Circuit drew clearly less than a year ago. And for anyone watching the growing tension between donor accountability and institutional autonomy in American religious life, the case raises questions that a court order alone cannot settle.

What the plaintiffs alleged

The lawsuit was filed in October 2024 by Katherine Leach, Garry K. Leach, Mark Browder, Terri Browder, and others described as former Gateway Church members and tithers. They named Gateway Church, founder Robert Morris, and founding elder Steve Dulin as defendants.

The plaintiffs accused the defendants of violating the Racketeer Influenced and Corrupt Organizations Act of 1970, the same federal statute originally designed to target organized crime. They also brought claims of fraud and intentional and negligent misrepresentation against Morris and Dulin in their individual capacities.

At the heart of the complaint was a specific promise the plaintiffs said the church made: that 15 percent of donations would go toward global missions and Jewish ministry partners. The plaintiffs further alleged that Gateway Church and Morris guaranteed donors could get a refund if they were dissatisfied with how their money was allocated. They said they had never been able to verify the church's use of donations through transparent accounting.

Robert Morris resigned from Gateway Church in June 2024. Both he and the church denied the allegations and asked the court to dismiss the case.

The legal doctrine that ended the case

Gateway's lawyers moved to dismiss the suit for lack of subject-matter jurisdiction more than six months before the ruling. Judge Mazzant initially denied that motion without prejudice, telling the defendants they could refile once the record was better developed.

The landscape shifted in September 2025, when the Fifth U.S. Circuit Court of Appeals issued its decision in McRaney v. North American Mission Board of the Southern Baptist Convention. In that case, ordained minister Will McRaney had sued the Southern Baptist Convention's mission board for defamation and intentional interference with business relationships. The Fifth Circuit upheld dismissal, ruling that resolving those claims would require a court to rule on "matters of faith and doctrine" and internal church management decisions. The court's conclusion was blunt: civil courts cannot adjudicate ecclesiastical matters.

Armed with that precedent, Gateway's attorneys filed an updated motion to dismiss last November. Judge Mazzant agreed that the McRaney ruling was binding. As reported by the Christian Post, the judge wrote in his opinion:

"The Court agrees that McRaney must inform its analysis this time around. McRaney is binding on the Court and the Fifth Circuit has put it simply: '[c]ivil courts cannot adjudicate ecclesiastical matters.'"

Judge Mazzant acknowledged that, on the face of the second amended complaint, the plaintiffs' claims "seemingly address Defendants' non-religious conduct." But he concluded that this conduct "centers around the allocation of tithing dollars to Gateway's 'many charitable purposes.'" Resolving the claims, he wrote, would "necessarily implicate questions of faith, scripture, and religious doctrine."

First Liberty Institute, a prominent religious liberty legal organization, filed an amicus brief supporting Gateway's motion to dismiss. The details of that brief were not made public in the ruling.

The plaintiff's response

Katherine Leach did not accept the ruling quietly. In a statement posted to Facebook on Wednesday, which she dated June 23, 2026, she framed the dismissal as proof that powerful religious institutions will spend whatever it takes to avoid financial scrutiny.

"Last night's Federal Court ruling, granting Gateway Church and the Defendants' Motion to Dismiss in the RICO class action lawsuit filed against them, is a stark reminder of the incredible lengths to which institutionally shielded organizations will go, and spend, to keep their financial statements in the dark."

Leach was particularly pointed about the ecclesiastical abstention doctrine, calling it "a First Amendment loophole to keep the books completely hidden." She noted that an earlier ruling had granted permission for discovery, allowing plaintiffs to seek church financial records, but that ruling was overturned by Tuesday's order.

The case raises a tension that courts have struggled with for decades: the line between protecting religious autonomy and holding institutions accountable when donors allege fraud. That tension has surfaced in other church disputes that have reached the courts, and the answers are rarely clean.

Leach also pushed back against any attempt by the defendants to claim total vindication. "Not so fast," she wrote. "Our attorneys are already actively reviewing yesterday's order and discussing all available options." Whether that means an appeal to the Fifth Circuit remains to be seen.

A doctrine with growing reach

The ecclesiastical abstention doctrine is not new. Its roots trace to nineteenth-century Supreme Court jurisprudence. But the Fifth Circuit's September 2025 McRaney decision gave the doctrine fresh teeth in a circuit that covers Texas, Louisiana, and Mississippi, states with some of the largest and most influential churches in the country.

In McRaney, the court dismissed claims that, on their surface, looked like ordinary tort and contract disputes. The key question was not whether the claims had legal merit in the abstract, but whether resolving them would force a court to interpret church decisions about mission, ministry, and internal governance. The Fifth Circuit said it would, and that was enough to close the door.

Judge Mazzant applied the same logic to the Gateway case. Even though the plaintiffs framed their claims as straightforward fraud, we gave money, you promised to spend it a certain way, you didn't, the judge concluded that tracing the flow of donated funds through a church's budget inevitably requires evaluating how a religious institution prioritizes its charitable purposes. And that, under McRaney, is off-limits.

This reasoning will frustrate anyone who believes churches should face the same financial accountability standards as secular nonprofits. But the doctrine exists for a reason the Founders understood well: when the government starts deciding which religious expenditures are legitimate and which are not, it is making theological judgments. The First Amendment was written to prevent exactly that.

The broader question of how courts handle religious liberty claims continues to generate significant litigation across the country, and this ruling adds another data point to a growing body of law that takes institutional religious freedom seriously.

Accountability without government overreach

None of this means churches are above scrutiny. It means the scrutiny has to come from the right place. Congregations can demand transparency from their leaders. Denominational bodies can impose financial standards. State attorneys general can investigate fraud under consumer protection statutes, a different legal avenue than a private RICO suit challenging internal fund allocation.

Leach's frustration is understandable on a human level. She and her fellow plaintiffs say they gave money based on specific promises and were never shown the receipts. Her statement included a pointed observation about church leaders who preach "honesty and transparency" and insist "independently audited financial statements" exist while "aggressively shielding themselves from having to publicly show their receipts."

"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."

That is a fair challenge, directed at the church, not at the court. The court's job was narrower: does the Constitution allow a federal judge to audit a church's internal spending decisions? Judge Mazzant said no, and the Fifth Circuit's precedent backed him up.

The case also arrives at a moment when legal battles involving religious institutions and government authority are intensifying across multiple fronts. Whether the issue is church governance, religious hiring practices, or institutional autonomy, the courts are increasingly being asked to draw lines that the political branches have declined to draw themselves.

Meanwhile, the Southern Baptist Convention has been navigating its own internal governance disputes, underscoring how much of the accountability debate within American Christianity is playing out inside the institutions rather than in courtrooms.

What comes next

The plaintiffs have signaled they may appeal. If they do, the case would go to the same Fifth Circuit that decided McRaney, not exactly friendly territory for their argument. But legal strategies can shift, and the plaintiffs' attorneys may attempt to distinguish their fraud claims from the kind of internal church governance questions that McRaney addressed.

Gateway Church and Robert Morris have not issued public statements in response to the ruling, at least not in the immediate aftermath. The church denied all allegations throughout the litigation and sought dismissal from the start.

For now, the case is closed. The donations at issue, described as millions of dollars, though no precise total has been made public, remain unaccounted for in any court-supervised process. The plaintiffs say they were promised transparency and never got it. The defendants say the Constitution protects them from this kind of judicial inquiry. A federal judge agreed with the defendants.

The First Amendment is not a license to defraud. But it does mean that when a church decides how to spend its offerings, the answer has to come from the congregation and the conscience, not from a federal courtroom. If Gateway's leaders made promises they didn't keep, the reckoning will have to come from somewhere other than a RICO suit.

That's not a loophole. That's the Constitution working as designed, even when the result is uncomfortable.