A Tennessee judge has ruled against a PCUSA minister, Rev. Roger Dermody, in his defamation case when a Presbyterian Mission Agency Board internal investigation found that four PCUSA employees had participated in the creation of an unauthorized mission work plan. Dermody filed a lawsuit against PCUSA, accusing the denomination of defamation. In its defense, the church specifically cited the Ministerial Exemption portion of the Ecclesiastical Abstention Doctrine, which prohibits the circuit court from engaging in fact-finding based on religious doctrine or internal church government.