• Key point. A church that dismisses an employee for sexual misconduct, and that offers the former employee financial assistance to pursue another profession, is not necessarily liable for future acts of sexual misconduct by the former employee in the course of his or her new profession.

• Key point. A church may be legally responsible for providing a positive and unqualified reference on a former worker if it knows that the worker presents a risk of harm and fails to disclose this information.

1. A Florida court ruled that churches and denominational agencies that dismiss clergy for sexual misconduct, and that later provide them with financial assistance to enable them to pursue studies in another profession, are not liable for injuries they cause in the course of their new profession. The court also addressed the important question of legal liability for providing misleading references. Three young men (the "plaintiffs") were sexually abused by a former Catholic priest long after he left the church and while he was a counselor with a secular counseling center. The plaintiffs sued the diocese and individual priests on the theory that they were liable because when the offending priest, a known pedophile, was removed from the priesthood, they provided financial assistance in order for him to complete a degree in counseling. Several years after this financial assistance and after the former priest obtained his degree and became licensed by the state as a counselor, he abused these plaintiffs. It was plaintiffs' contention that "but for" this financial assistance, the priest would not have received a degree, would not have become a counselor, would not have been licensed by the state, would not have become employed by the secular counseling center, and would not have abused these plaintiffs.