Belya v. Metropolitan Hilarion
Case Snapshot
Father Alexander Belya is a now-defrocked priest in the Russian Orthodox Church Outside of Russia (ROCOR). In the midst of an internal ecclesiastical uproar about whether he met the qualifications necessary to be elected bishop, Father Alexander’s diocesan leaders wrote a letter explaining that Father Alexander was not qualified to be a bishop and that he had not been elected pursuant to church requirements. The letter claimed his conduct violated church laws and called on the Church to suspend Father Alexander and to open an investigation. The head of ROCOR—Metropolitan Hilarion—then suspended Father Alexander from performing priestly duties pending an investigation. Rather than submit to an investigation, Father Alexander left ROCOR and sued his former church, Metropolitan Hilarion, and other Church leaders for defamation. Courts across the country have made it clear that civil courts should not be involved in the internal affairs of religious organizations, after years of litigation, a federal court in New York has dismissed all of Father Alexander’s claims against the Church. Submitting the Church to a trial over its communications about who should be a bishop would punish it for exercising its right to choose its own clergy, which violates both the Free Exercise Clause and Establishment Clause of the First Amendment.
Status
Becket is arguing that the First Amendment protects churches’ right to choose or remove their clergy without government interference. On March 31, 2025, a federal court ruled in favor of ROCOR, saying that “a trial in the case would drag the Court and jury into matters of faith, spiritual doctrine, and internal church governance—precisely what the church-autonomy doctrine is designed to prevent.”
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Case Summary
ROCOR: A History of dealing with Big Government
The Russian Orthodox Church Outside of Russia (ROCOR) began in the 1920s after a contingent of Russian Orthodox priests and bishops were forced out of Russia by the Bolshevik government. Following their exile, the bishops went to Western Europe and eventually to the United States.
Over the past century, ROCOR has grown across the world, especially in the United States. Today, of their 400 parishes worldwide, 232 are within the U.S. Following the fall of the Soviet Union, ROCOR and the Moscow Patriarchate agreed to an act of communion in May 2007, reestablishing their canonical ties.
An Internal Dispute
Father Alexander Belya was a ROCOR priest for several years. In the midst of an internal ecclesiastical uproar about whether he met the qualifications necessary to be elected bishop, Father Alexander’s diocesan leaders wrote a letter to the Synod—the executive organ of the church’s highest ecclesiastical body—describing complaints about Father Alexander’s conduct that violated church laws and explained that he had not been elected pursuant to church requirements. The letter also noted several irregularities under church law in the documents that falsely claimed he had been elected, and called on Metropolitan Hilarion to suspend Father Alexander from priestly duties and to open a Church investigation into the alleged election. Metropolitan Hilarion then suspended Father Alexander. Rather than submit to the investigation, Father Alexander left ROCOR and sued the Church, Metropolitan Hilarion, and other Church leaders for defamation. He claims damages for the loss of income from members leaving his congregation, and for “severely impaired reputation and standing” within the ROCOR community.
Defending Church Autonomy:
Religious freedom has allowed ROCOR to thrive in the United States. This freedom includes protections from government interference in churches’ internal religious affairs—especially in their decisions related to the selection, discipline, or removal of clergy. But this right means little if a church can be sued for communicating these decisions to its members.
After the Southern District of New York refused to dismiss Father Alexander’s suit, Becket stepped in and appealed to the Second Circuit Court of Appeals. On August 17, 2022, the Second Circuit ruled against the church, declining to protect ROCOR’s First Amendment rights. After the Second Circuit denied rehearing and the U.S. Supreme Court declined to take the case, the case continued in federal district court.
On March 4, 2025, the Southern District of New York heard the case. Later that month, the court ruled in favor of ROCOR and dismissed Belya’s case, saying that “a trial in the case would drag the Court and jury into matters of faith, spiritual doctrine, and internal church governance—precisely what the church-autonomy doctrine is designed to prevent.”
The Church is also represented by Feerick Nugent MacCartney, PLLC.
Importance for Religious Liberty:
- Freedom of religious groups to choose their own leaders: Churches and other religious groups have the right to select, discipline, and, if necessary, remove their leaders without government interference. Only the church—not a court—gets to say who the bishop is. This right is protected by a First Amendment principle called the “ministerial exception.”
- Freedom of religious groups from state intrusion on religious affairs: Churches and religious organizations have a right to live, teach, and govern in accordance with the tenets of their faith. When the government unjustly interferes in internal church affairs, the separation of church and state is threatened. The First Amendment ensures a church’s right to self-definition and free association.