Texas Senate Bill 694: Civil Immunity for Faith-Based and Nonprofit Security Teams

Introduction

In recent years, faith-based organizations and nonprofits have faced increasing security challenges, including high-profile incidents of violence at houses of worship. In response, Texas enacted Senate Bill 694 (SB 694), a law designed to provide civil immunity to religious organizations and their security personnel—both employees and volunteers—when acting within the scope of their security duties. This legislation, effective September 1, 2023, has significant implications for how churches and other faith-based nonprofits approach security, liability, and risk management. This blog post provides a comprehensive summary of SB 694, including its purpose, scope, eligibility conditions for immunity, pros and cons, and actionable insights for organizations considering compliance.

The primary purpose of SB 694 is to address the legal risks faced by faith-based organizations and their security teams, particularly in the wake of tragic events such as the 2017 Sutherland Springs church shooting, which underscored the vulnerability of religious gatherings to targeted violence. Prior to SB 694, Texas law provided some immunity to volunteers of charitable organizations, but there was ambiguity regarding the liability exposure of employees and volunteers specifically tasked with security functions in religious settings.

Texas Senate Bill 694: Civil Immunity for Faith-Based and Nonprofit Security Teams

SB 694 was introduced by Senator Bryan Hughes and received bipartisan support in the Texas Legislature. The bill amends Chapter 84 of the Texas Civil Practice and Remedies Code, extending civil immunity to both employees and volunteers providing security services for religious organizations. The legislative intent was to encourage faith-based organizations to establish or maintain security teams without the deterrent of potential civil lawsuits, thereby enhancing the safety of congregants and staff.

Scope and Definitions

SB 694 applies specifically to “religious organizations,” defined as charitable organizations whose primary purpose is religious, including religious schools and charities, provided they maintain tax-exempt status under Section 501(c)(3) of the Internal Revenue Code. The law covers both employees and volunteers designated as “security personnel,” meaning individuals hired or assigned by the organization to provide security services.

Key Definitions:

Religious Organization: A charitable entity with a primary religious purpose, including religious schools and charities, maintaining 501(c)(3) status.
Security Personnel: Employees or volunteers whose duties include providing security services to the organization.

The law is prospective, applying only to causes of action arising on or after September 1, 2023.

Conditions for Immunity: Eligibility and Limitations

Statutory Language

Under Section 84.0067 of the Texas Civil Practice and Remedies Code, as added by SB 694, a religious organization or its security personnel are immune from civil liability for any act or omission resulting in death, damage, or injury if:

The security personnel were acting within the course and scope of their employment or volunteer duties to provide security services to the organization.
Immunity applies even to intentional acts and acts involving the possession or use of a firearm, notwithstanding previous statutory limitations.

Eligibility Checklist

To qualify for immunity under SB 694, the following conditions must be met:

Condition	Description
1. Organizational Status	The entity must be a religious organization as defined by Texas law and maintain 501(c)(3) status.
2. Security Personnel Status	The individual must be an employee or a documented volunteer assigned to security duties.
3. Scope of Duties	The act or omission must occur within the course and scope of security-related employment or volunteer functions.
4. Documentation and Training	Proper documentation of assignment and, ideally, evidence of relevant training and protocols.
5. No Willful Misconduct or Criminal Acts	Immunity does not extend to acts outside the scope of duties, willful misconduct, or criminal activity.
6. Prospective Application	The incident must occur on or after September 1, 2023.

Detailed Analysis:

Organizational Status: Only organizations meeting the statutory definition of a religious organization are covered. This includes churches, synagogues, mosques, and religious schools or charities, provided they are recognized as 501(c)(3) nonprofits.
Security Personnel Status: Immunity extends to both employees and volunteers, but only if their official duties include providing security services. Volunteers must be properly documented as part of the security team.
Scope of Duties: The act or omission must occur while the individual is performing security functions for the organization. Actions outside this scope (e.g., personal disputes, unauthorized use of force) are not protected.
Documentation and Training: While the statute does not mandate specific training or credentialing, best practices and insurance requirements strongly recommend thorough documentation of team assignments, training records, and incident reports to demonstrate compliance and good faith.
No Willful Misconduct or Criminal Acts: Immunity does not shield individuals from liability for acts outside the scope of their duties, criminal conduct, or gross negligence. The law specifically overrides a prior limitation that excluded intentional acts from immunity, but only when such acts are within the scope of security duties.
Prospective Application: The law applies only to incidents occurring after its effective date; prior incidents are not covered.

Practical Implications for Faith-Based Security Teams

Enhanced Legal Protection

The most immediate impact of SB 694 is the reduction of civil liability risk for religious organizations and their security teams. By providing immunity for acts or omissions committed in the course of security duties—including the use of force or firearms—SB 694 encourages organizations to form or maintain security teams without the fear of devastating lawsuits.

Encouragement of Volunteerism

Many smaller congregations rely on volunteers rather than professional security staff. SB 694’s explicit inclusion of volunteers as eligible for immunity removes a significant barrier to recruiting and retaining volunteer security personnel, which is especially important for resource-constrained organizations.

Training and Documentation

Although the law does not mandate specific training, best practices dictate that organizations should:

Provide regular, scenario-based training on de-escalation, use of force, and emergency response.
Maintain thorough documentation of team assignments, training records, and incident reports.
Develop and regularly update security policies and procedures, including clear protocols for communication and incident response.

Insurance and Risk Management

While SB 694 reduces civil liability, it does not eliminate the need for appropriate insurance coverage. Many standard church liability policies exclude intentional acts or use of force, so organizations should review their policies and consider supplemental coverage tailored for security teams.

Interaction with Criminal Law

SB 694 provides civil immunity only; it does not shield individuals from criminal prosecution for unlawful acts. Security personnel must still comply with Texas criminal law regarding the use of force, firearms, and self-defense. Training should include legal standards for reasonable and proportionate force, as well as protocols for interacting with law enforcement after an incident.

Pros and Cons of SB 694

Pros

1. Legal Clarity and Protection SB 694 provides clear statutory immunity for religious organizations and their security personnel, reducing the risk of costly civil litigation arising from security incidents. This legal certainty is particularly valuable in the aftermath of violent events, where lawsuits often follow even justified defensive actions.

2. Encouragement of Security Preparedness By lowering the liability barrier, the law encourages more faith-based organizations to establish or maintain security teams, enhancing the overall safety of congregants and staff.

3. Support for Volunteerism Explicitly including volunteers in the immunity provision makes it easier for smaller organizations to recruit and retain security team members, addressing a critical resource gap for many congregations.

4. Alignment with Federal Law SB 694 complements the federal Volunteer Protection Act of 1997, which provides some immunity for volunteers of nonprofits, but clarifies and extends protection under Texas law to both employees and volunteers engaged in security functions.

5. Flexibility for Organizational Policies The law allows organizations to tailor their security protocols to their unique needs, without imposing rigid state-mandated training or credentialing requirements. This flexibility is especially important for diverse faith communities with varying resources and risk profiles.

Cons

1. Potential for Reduced Accountability Critics argue that broad immunity could reduce accountability for security personnel, especially in cases where excessive or inappropriate force is used. While the law does not protect criminal acts, the civil immunity provision may make it harder for victims of wrongful conduct to seek redress in court.

2. Risk of Inadequate Training Because SB 694 does not require specific training or credentialing, there is a risk that some organizations may deploy undertrained or unqualified individuals in security roles, increasing the likelihood of mistakes or escalation during incidents.

3. Insurance Gaps Remain Civil immunity under SB 694 does not guarantee insurance coverage. Many insurers exclude intentional acts or use of firearms from standard liability policies, so organizations may still face financial exposure if their coverage is inadequate or if claims fall outside the scope of immunity.

4. No Protection from Criminal Liability The law does not shield individuals from criminal prosecution. Security personnel who violate criminal statutes—such as by using excessive force or acting outside the scope of their duties—remain subject to arrest and prosecution.

5. Possible Discouraging Effect on Victims Some legal experts and advocacy groups worry that broad immunity could discourage legitimate claims by individuals harmed by negligent or reckless security actions, potentially undermining civil justice for victims.

Comparative Perspective: Other States and Federal Law

Texas is not alone in seeking to protect faith-based organizations and their security teams from civil liability. The federal Volunteer Protection Act (VPA) of 1997 provides some immunity for volunteers of nonprofits, but its protections are limited to acts of ordinary negligence and do not extend to employees or intentional acts. SB 694 goes further by:

Including both employees and volunteers.
Extending immunity to intentional acts (if within the scope of security duties).
Explicitly covering acts involving firearms.

Other states have adopted similar measures, though the scope and eligibility criteria vary. For example, some states require specific training or licensing for armed security personnel, while others limit immunity to volunteers or exclude intentional acts from protection. Organizations operating in multiple states should consult legal counsel to ensure compliance with all applicable laws.

States with faith-based security team immunity and pending proposals

Organizations are increasingly seeing civil immunity frameworks for volunteer security teams, but eligibility, scope, and carve-outs differ widely. Below is a practical list of enacted laws and notable proposals, including Pennsylvania’s current legislation, to help multistate ministries and nonprofits benchmark requirements.

States with Enacted Protections

Mississippi – Church Protection Act (2016): Allows churches to form armed security ministries with liability protections. Requires training and church authorization. The Mississippi Church Protection Act is codified at Mississippi Code § 45-9-171. Originally enacted in 2016 (HB 786), it has since been amended, most notably by HB 1018 in 2020, to clarify recordkeeping and training requirements for church security teams. The law is currently in effect.

Arkansas – Church Carry/Protection (2013+): Permits concealed carry in churches; legal protections apply when churches designate security functions. Arkansas law regarding firearms in churches is primarily found in Arkansas Code § 5-73-306 (Prohibited Places) and related statutes. The law has evolved through several legislative acts, notably Act 67 (2013), Act 562 (2017), and Act 859 (2017), which together permit churches to determine their own firearms policies and allow certain licensees to carry concealed handguns on church property unless specifically prohibited.

Florida – Volunteer Protection Act (F.S. § 768.1355): Grants civil immunity to nonprofit volunteers, including church safety teams, acting within scope of duties. The Act applies to any person who volunteers for a nonprofit organization (including churches, which are typically 501(c)(3) entities), performing services without compensation (other than reimbursement for expenses). Volunteer church safety or security team members are covered, provided they act within the scope of their official duties and meet the Act’s requirements.

Missouri – RSMo § 571.107: Churches may authorize individuals to carry concealed firearms on their premises. By default, concealed carry is prohibited in churches unless the minister or person(s) representing the religious organization consents. Churches may designate armed security personnel or volunteers, provided they are authorized by the church leadership.
Idaho – HB 601 (2024) was enacted and is now codified as Idaho Code § 5-348. The law is in full force and effect as of July 1, 2024. The law grants civil immunity to volunteer security personnel serving religious organizations and to the organizations themselves for actions taken in providing safety, security, or protection at religious gatherings.

Georgia – OCGA § 51-1-20.2: Provides immunity to volunteer security personnel under certain conditions. The statute applies to uncompensated officers, directors, trustees, and members of nonprofit organizations, including churches. Volunteer security personnel serving in an official capacity for a church may be covered, provided they are not compensated and act within the scope of their duties.

Pending or Proposed Legislation

Pennsylvania – HB 1681 (2025 session): Would grant civil immunity to designated security officers of religious organizations for actions taken in defense of congregants or property. Immunity excludes reckless, malicious, or grossly negligent conduct.

Arkansas – As of March 2025, a bill (HB 1306) was introduced to provide explicit immunity for volunteer church security teams, contingent on training defined by the church. The bill has not yet become law but reflects legislative intent to expand protections for volunteer security ministries.

Other states are monitoring this trend, with proposals emerging in legislatures to extend volunteer immunity to faith-based contexts, often modeled after Mississippi’s and Texas’s frameworks.

Common Conditions for Immunity

Good-faith actions: Immunity applies only when volunteers act responsibly within assigned duties.
Training requirements: Some states mandate firearms or de-escalation training for armed volunteers.
Volunteer status: Immunity usually applies only to unpaid volunteers, not paid staff.
Exclusions: Gross negligence, intentional misconduct, or criminal acts are never protected.
Licensing triggers: Armed or uniformed roles often require compliance with state guard card or PPO/PSE licensing.

Actionable Insights and Compliance Checklist

For faith-based and nonprofit organizations considering compliance with SB 694, the following steps are recommended:

1. Review and Update Safety & Security Policies

Ensure your organization’s bylaws and policies clearly define the roles and responsibilities of security personnel (both employees and volunteers).
Specify the scope of security duties and the chain of command during incidents.

2. Document Security Team Assignments

Maintain written records of all individuals assigned to security roles, including job descriptions or volunteer agreements.
Require background checks and vetting for all security personnel.

3. Implement Regular Training

Provide ongoing training in de-escalation, use of force, emergency response, and legal standards for self-defense.
Conduct scenario-based drills and tabletop exercises at least quarterly.

4. Maintain Training and Incident Records

Keep detailed records of all training sessions, attendance, and topics covered.
Document all security-related incidents, including actions taken and outcomes.

5. Review Insurance Coverage

Consult with your insurance provider to ensure that your policy covers security team activities, including intentional acts and use of force.
Consider supplemental coverage tailored for security volunteers and employees.

6. Communicate with Law Enforcement

Establish relationships with local law enforcement agencies and invite them to participate in security planning and training.
Develop protocols for post-incident communication and cooperation with authorities.

7. Engage the Congregation

Educate staff, volunteers, and congregants about security policies and procedures.
Foster a culture of safety and preparedness without creating unnecessary fear or anxiety.

8. Monitor Legal Developments

Stay informed about changes in state and federal law affecting nonprofit and faith-based security teams.
Consult legal counsel for guidance on complex or ambiguous situations.

Communication and Community Relations

Effective security is not just about physical measures; it also requires clear communication and strong community relations. Organizations should:

Develop communication protocols for emergencies, including mass notification systems and designated spokespersons.
Encourage open dialogue with congregants about security concerns and the rationale for security measures.
Balance the need for safety with the organization’s mission of hospitality and inclusivity.

Conclusion

Texas Senate Bill 694 represents a significant shift in the legal landscape for faith-based and nonprofit security teams. By providing civil immunity for acts or omissions committed in the course of security duties, the law empowers organizations to take proactive steps to protect their communities without the constant threat of civil litigation. However, with this protection comes the responsibility to ensure that security personnel are properly trained, documented, and supervised. Organizations must also remain vigilant about insurance coverage, compliance with criminal law, and the ethical implications of their security practices.

For faith-based and nonprofit leaders, the actionable steps outlined above provide a roadmap for leveraging the protections of SB 694 while maintaining the highest standards of safety, accountability, and community trust.

Disclaimer: This blog post is for informational purposes only and does not constitute legal advice. Organizations should consult qualified legal counsel for guidance specific to their circumstances.

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