Richards Obtains Iowa Supreme Court Ruling Involving First Amendment Protections To Communications Made Within A Church Community

Photo of Amanda M. Richards

On May 21, 2021, the Iowa Supreme Court unanimously affirmed the grant of summary judgment to a pastor and his church for claims of breach of fiduciary duty and defamation. The pastor and the church were represented by member/partner Amanda Richards.

In 2017, the Plaintiff, a former member of the church, filed a lawsuit against his former church and pastor after his pastor shared information with his church small group, fellow pastors, and administrative staff relating to his contentious divorce and accusations of child abuse. The Plaintiff asserted his pastor and church breached fiduciary duties of loyalty, objectivity, and confidentiality, and also brought a defamation and invasion of privacy.

Following a four year litigation, the church ultimately was granted summary judgment pursuant to the Ecclesiastical Shield of the United States Constitution which prohibits courts from interfering in or upon religious practices and doctrine of the church.

The Plaintiff appealed and the Iowa Supreme Court accepted the case. Oral arguments took place on March 24, 2021. On May 21, 2021, Justice Mansfield authored the opinion affirming the District Court’s grant of judgment to the church and pastor. The Court held that “deciding liability would not be a simple task of applying a well-defined secular standard but would involve weighing of both marital counseling standards and the norms by which the church is governed”. The Court following its prior precedent found that “the means by which the church official chose to counsel and advise the congregation is outside the purview of the government”.

In affirming the District Court, the Court held that determining whether a pastor breached a fiduciary duty of confidentiality arising out of group discipleship discussions would require the Iowa Courts to interpret the church doctrine and practices and therefore, “such a claim cannot proceed in our courts”.

The decision in its entirety can be read HERE.