Disability Plan Offered By Nondenominational Christian Ministry Was Not A "Church Plan" That Fell Outside ERISA

In this case, the United States District Court held that a long-term disability plan offered to employees by a Christian ministry was not exempt from the Employee Retirement Income Security Act (ERISA) as a "church plan" where the ministry, which acted primarily as vendor of Bible study products and trained Bible study teachers, did not constitute a "church" under ERISA.

Although it had status as a nonprofit entity pursuant to the Internal Revenue Code, the nondenominational ministry was not funded or governed by a specific religious institution, did not require its employees or board members to be members of any particular Christian denomination, did not have an established congregation, did not have a clergyman on staff, and did not conduct religious services on a regular basis. Thus, an employee's state-law claims arising from the denial of a policy claim were preempted by ERISA.

Goetz v. Greater Georgia Life Ins. Co.

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