The Texas Supreme Court has ruled that a church can't be held liable for the injuries that a teen alleged she suffered during the course of an exorcism. A jury had previously awarded her $300,000, but that award was later reduced to less than $200,000. The justices, in a 6-3 decision, decided that holding the church accountable would have a "chilling effect" on religious matters protected by the First Amendment. In particular, the majority held that it could not determine "matters of religious doctrine."
"Although the Free Exercise Clause does not categorically insulate religious conduct from judicial scrutiny, it prohibits courts from deciding issues of religious doctrine.... Chief Justice Jefferson asserts, however, that we go too far in protecting religious doctrine in this case, and, in effect, eliminate mental anguish as an element of damage against tortfeasors who allege their conduct was motivated by religious conviction. ___ S.W.3d at ___ (Jefferson, C.J., dissenting). That, of course, is not our intent. We do not mean to imply that “under the cloak of religion, persons may, with impunity,” commit intentional torts upon their religious adherents....Freedom to believe may be absolute, but freedom of conduct is not, and “conduct even under religious guise remains subject to regulation for the protection of society.”... Moreover, religious practices that threaten the public’s health, safety, or general welfare cannot be tolerated as protected religious belief....But religious practices that might offend the rights or sensibilities of a non-believer outside the church are entitled to greater latitude when applied to an adherent within the church. ...Particularly, when the adherent’s claim, as here, involves only intangible, emotional damages allegedly caused by a sincerely held religious belief, courts must carefully scrutinize the circumstances so as not to become entangled in a religious dispute.... And while we can imagine circumstances under which an adherent might have a claim for compensable emotional damages as a consequence of religiously motivated conduct, this is not such a case.
"The “laying of hands” and the presence of demons are part of the church’s belief system and accepted as such by its adherents. These practices are not normally dangerous or unusual and apparently arise in the church with some regularity. They are thus to be expected and are accepted by those in the church. That a particular member may find the practice emotionally disturbing and non-consensual when applied to her does not transform the dispute into a secular matter. “Courts are not arbiters of religious interpretation,” and the First Amendment does not cease to apply when parishioners disagree over church doctrine or practices because “it is not within the judicial function and judicial competence to inquire whether the petitioner or his fellow worker more correctly perceived the commands of their common faith.” ...Because determining the circumstances of Laura’s emotional injuries would, by its very nature, draw the Court into forbidden religious terrain, we conclude that Laura has failed to state a cognizable, secular claim in this case.... The Free Exercise Clause prohibits courts from deciding issues of religious doctrine. Here, the psychological effect of church belief in demons and the appropriateness of its belief in “laying hands” are at issue. Because providing a remedy for the very real, but religiously motivated emotional distress in this case would require us to take sides in what is essentially a religious controversy, we cannot resolve that dispute. Accordingly, we reverse the court of appeals’ judgment and dismiss the case."
Read the entire opinion via this link.
