Key point 10-04.2. Some courts have found churches not liable on the basis of negligent selection for the molestation of a minor by a church worker since the church exercised reasonable care in the selection of the worker.
Key point 10-09.2. Some courts have found churches not liable on the basis of negligent supervision for a worker's acts of child molestation on the ground that the church exercised reasonable care in the supervision of the victim and of its own programs and activities.
Key point 10-18.2. Most courts have refused to hold denominational agencies liable for the acts of affiliated ministers and churches, either because of First Amendment considerations or because the relationship between the denominational agency and affiliated church or minister is too remote to support liability.
* A federal court in New York ruled that a Catholic archdiocese was not responsible on the basis of negligent hiring, supervision, or retention for the sexual misconduct of a priest, since it had no knowledge of prior wrongful acts. A Catholic priest asked a female parishioner (the "plaintiff") if she had been sexually abused as a child. After the plaintiff told him that she had been abused, he informed her that he had helped other women with a history of abuse. In the course of three private "sessions" the priest engaged in various forms of sexual contact with the plaintiff as part of his "therapy" to help relieve her of the effects of the prior abuse. The plaintiff did not disclose this abuse until she began meeting with a therapist. The therapist promptly informed the victims' assistance coordinator of the archdiocese of the plaintiff's allegations. This was the first notice to the archdiocese of the plaintiff's allegations concerning the priest, or of any other claims of sexual abuse made against him.