• Key point. Several courts have concluded that churches and denominational agencies cannot be legally responsible for a minister's sexual misconduct, since allowing such organizations to be sued for failing to exercise sufficient care in the selection, training, or supervision of ministers would violate the first amendment guaranty of religious freedom. A minority of courts have ruled that the first amendment does not prevent churches from being sued in such cases.

A federal court in Rhode Island ruled that the first amendment did not prevent it from resolving a lawsuit brought by victims of clergy sexual misconduct against church officials. Three adult males sued diocesan officials for injuries they allegedly sustained when they were molested by two priests in the 1970s and 1980s. The victims claimed that prior to the acts of molestation, the diocese knew that the priests were pedophiles and not only failed to take appropriate preventative action, but also actively concealed the priests' sexual misconduct. The diocese claimed that the first amendment prevented the civil courts from resolving these claims.

Freedom of Religion

The court conceded that an internal church dispute cannot be resolved by a civil court if resolution of the dispute would require the court to interpret religious doctrine or ecclesiastical law. But the court rejected the proposition that a secular court lacks jurisdiction over a case simply because it "calls into question the conduct of someone who is a church official." The court concluded that this dispute was not an internal church matter: