Court Decisions Rejecting Negligent Supervision Claims
Key point 10-09.02. 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.
This section reviews court decisions in which a church or other religious organization was found not liable on the basis of negligent supervision for a worker's acts of child molestation.
Case Studies
- A federal appeals court ruled that an archdiocese was not responsible for the alleged molestation of a minor by a priest.[116] Tichenor v. Roman Catholic Church, 32 F.3d 953 (5th Cir. 1994). An adult male sued a priest, a local Catholic church, and an archdiocese claiming that while he was a minor the priest performed illicit sexual acts upon him. The plaintiff alleged that the archdiocese and church were liable because they knew or should have known that illicit acts were being performed on their premises and at the priest's home. He charged that they failed to protect him or take appropriate measures to ascertain or correct the situation. Moreover, he alleged that they knew or should have known that they were fostering the priest's illicit activities and providing him with the means with which to conduct such activities. In rejecting the plaintiff's claim that the archdiocese was responsible for his injuries on the basis of negligent supervision, the court observed: "Employers do not have a duty to supervise their employees when the employees are off-duty or not working. Employers also are not liable for failure to supervise when the employee engages in independent criminal conduct which results in the plaintiff's injuries. Moreover, an employer's duty to supervise does not include a duty to uncover his employees' concealed, clandestine, personal activities. … It is unfortunate, to say the least, that the frequency with which these cases have surfaced suggests that the clergy at [the local church] were naive. There is, however, nothing to indicate that the archdiocese or [church] knew or should have known of what was taking place in [the priest's] private world."
- The Alabama Supreme Court ruled that a church was not legally responsible for the sexual molestation of a 10-year-old girl.[117] N.J. v. Greater Emanuel Temple Holiness Church, 611 So.2d 1036 (Ala. 1992). A 10-year-old girl lived near a church that operated a kindergarten at which her aunt was the head teacher. The girl's mother instructed her to walk to the church following school, and then have her aunt escort her home when she quit work at 5:30 p.m. One day, while waiting on the church property for her aunt, the girl was raped by an adolescent male. The girl was raped a second time by the same adolescent several days later. The girl did not disclose the rapes to anyone until, during a routine medical examination, the family physician found evidence of sexual relations. The girl at first denied that she had ever engaged in sexual relations, but later acknowledged that the adolescent male (who was known to her) had raped her on two occasions. The girl's mother later filed a lawsuit against the church, claiming that it had failed to use "due care" in watching and supervising the girl "thereby allowing" the rape to occur. A trial court ruled in favor of the church, and the mother appealed. The state supreme court agreed that the church could not be legally responsible for the girl's injuries. The court acknowledged that there may have been an oral agreement between the mother and the aunt to care for the girl after school. However, the court insisted that "there was no evidence that [the victim] was, in fact, under the care of the church." The court continued, "[T]he mere fact that an injury has occurred is not evidence of negligence and … in negligent supervision cases negligence will not be found by inference. Assuming, without deciding, that there was an agreement that [the victim] was to be supervised and cared for by the church, [the victim] failed to produce any evidence demonstrating that the church negligently supervised her on the days she says she was assaulted and raped. Thus, a finding that [the girl] was negligently supervised on the days in question could be had only by inference [and] we may not draw that inference here." The court also emphasized that churches ordinarily cannot be found guilty of negligent supervision without some special relationship or special circumstances that were not present in this case: "[T]he general rule is that absent special relationships or circumstances, a person has no duty to protect another from criminal acts of a third person. … [A defendant cannot] be held liable for the criminal act of a third party unless the defendant knew or had reason to know that the criminal act was about to occur on the defendant's premises."
- A California court ruled that a Catholic church was not responsible on the basis of negligent supervision for a priest's acts of child molestation, since "nearly all" of the acts of molestation occurred when the priest "took the victim from her home to various public places and hotels."[118] Roman Catholic Bishop v. Superior Court, 50 Cal. Rptr.2d 399 (Cal. App. 1996).
- The Minnesota Supreme Court ruled that a school was not liable on the basis of negligent supervision for the sexual seduction of a high school student by a female teacher.[119] P.L. v. Aubert, 545 N.W.2d 666 (Minn. 1996). See also Doe 169 v. Brandon, 845 N.W.2d 174 (Minn. 2014). The teacher used a counseling relationship with a male student as the basis for a sexual relationship that continued for several months. Most of the sexual encounters occurred during regular school hours on school premises. The victim later sued the school, claiming that it was responsible for his injuries on the basis of negligent supervision. In rejecting the victim's claim that the school was guilty of negligent supervision, the court observed: "[The school] performed standard teacher evaluations of [the teacher]. In addition to the evaluations [school officials] made several unannounced visits to [the teacher's] classrooms. Because the school had no public address system, all messages were hand-delivered by staff and students to classrooms throughout the course of the school day. Even with all of this interaction during the school day, the [secret] relationship between teacher and student was never observed. A school cannot be held liable for actions that are not foreseeable when reasonable measures of supervision are employed to insure adequate educational duties are being performed by the teachers, and there is adequate consideration being given for the safety and welfare of all students in the school. The safety and welfare of the students in a school setting is paramount. However, in this case, closer vigilance would not have uncovered the relationship because both participants worked hard to conceal it."
- A New York Court ruled that a church was not liable on the basis of negligent supervision for the sexual misconduct of an employee. It concluded: "As to theories concerning supervision or retention, we note the employee had worked as a coordinator at the church for at least five years prior to the alleged incident. During that period, the church did not receive any complaints about the employee, and did not know of anyone else who had received complaints about him. Plaintiff himself had never heard of any complaints, and the employee had never been convicted of any crime."[120] Osvaldo D. v. Rector Church Wardens and Vestrymen of the Parish of Trinity Church of New York, 834 N.Y.S.2d 94 (N.Y.A.D. 2007). See also Bouchard v. New York Archdiocese, 719 F.Supp.2d 255 (S.D.N.Y. 2010)..
- An Ohio court ruled that a church was not responsible for the rape of a six-year-old boy occurring on church property during Sunday school.[121] Bender v. First Church of the Nazarene 571 N.E.2d 475 (Ohio App. 1989). The boy attended a Sunday school class of about 45 first and second graders. One adult female teacher was present on the day of the rape along with two teenage volunteers (one male and one female). During "story time," the victim became disruptive, and the teacher allowed the male volunteer to "take him back and color" in an unused room. The adult teacher did not check on the boy for the remainder of the Sunday school session. The boy's mother alleged that the male volunteer took her son to an unused room, raped him, and threatened to kill him if he "told anyone." The boy and his mother later sued the church, claiming that the boy's injuries were a result of the church's "negligent supervision" of its agents. The court noted that "negligence does not consist of failing to take extraordinary measures which hindsight demonstrates would have been helpful." The court further observed that a church is "not an insurer of the safety" of persons on its premises, but rather has only a "duty of ordinary care to avoid injury consistent with [existing] facts and circumstances." The court emphasized that the victim and his mother "have presented no evidence that [the church] knew, or in the exercise of reasonable diligence should have known of or anticipated a criminal sexual assault by [the alleged rapist] upon another." The victim and his mother placed great significance upon evidence that "a similar incident had occurred several years earlier." In rejecting the relevance of this evidence the court observed simply that "there is no evidence that the church or its agents knew, or in the exercise of diligence, should have known of such prior activity."
- A Texas court rejected a parent's claim that a church was responsible on the basis of negligent supervision for the molestation of her daughter by a youth pastor.[122] Eckler v. The General Council of the Assemblies of God, 784 S.W.2d 935 (Tex. App. 1990). A mother enrolled her daughter in a private school operated by a local church. A few months later, the mother discovered three sexually explicit letters which she believed were correspondence between her daughter and the youth pastor (who also taught at the school). These letters, along with explicit entries in the daughter's diary, led the mother to believe that her daughter and the youth pastor were engaging in sexual activities. She took the evidence to the senior minister of the church, asking for his assistance. Unsatisfied with the investigation, the mother sued the church and a national denominational agency. She claimed that the national church was responsible for the youth pastor's acts on the basis of negligent supervision. In rejecting this claim, the court noted that negligence requires proof that someone's conduct actually caused injuries to another, and it concluded that the national church's act of ordaining or licensing clergy in no way was the cause of the girl's injuries. Further, in rejecting the plaintiff's claim that the national church used "less than ordinary care" in discharging its "continuing duty" to monitor and supervise its clergy, the court observed that the national church "exercises no supervisory powers over the local ministers" and "is not responsible for the day-to-day oversight of the ministers." Since the national church had no duty to supervise clergy, "it is impossible that lack of supervision … was a substantial factor in causing plaintiff's injuries."
Table of Contents
-
1Definitions and Status
-
§ 1.01Distinctions Between the Terms Pastor, Clergy, Minister
-
§ 1.02Definition of the Terms Pastor, Clergy, Minister — In General
-
§ 1.03Status—Employee or Self Employed
-
§ 1.03.01Social Security
-
§ 1.03.02Income Taxes
-
§ 1.03.03Retirement Plans
-
§ 1.03.04Legal Liability
-
§ 1.03.05Miscellaneous Federal and State Statutes
-
-
§ 1.04Status—Ordained, Commissioned, or Licensed
2The Pastor-Church Relationship
-
§ 2.01Initiating the Relationship—In General
-
§ 2.01.01Congregational Churches
-
§ 2.01.02Hierarchical Churches
-
§ 2.01.03Compliance with a Church's Governing Instrument in the Selection of a Minister
-
§ 2.01.04Civil Court Review of Clergy Selection Disputes—the General Rule of Non-Intervention
-
§ 2.01.05Civil Court Review of Clergy Selection Disputes—Limited Exceptions to the General Rule
-
§ 2.01.06Negligent Selection
-
-
§ 2.02The Contract
-
§ 2.03Compensation
-
§ 2.04Termination
3Authority, Rights, and Privileges
-
§ 3.01General Scope of a Minister's Authority
-
§ 3.02Officer of the Church Corporation
-
§ 3.03Property Matters
-
§ 3.04Performance of Marriage Ceremonies
-
§ 3.05Exemption from Military Duty
-
§ 3.06Exemption From Jury Duty
-
§ 3.07The Clergy-Penitent Privilege—In General
-
§ 3.07.01A "Communication"
-
§ 3.07.02Made in Confidence
-
§ 3.07.03To a Minister
-
§ 3.07.04Acting in a Professional Capacity as a Spiritual Adviser
-
§ 3.07.05In the Course of Discipline
-
-
§ 3.08The Clergy-Penitent Privilege—Miscellaneous Issues
-
§ 3.08.01Clergy-Parishioner Relationship
-
§ 3.08.02Marriage Counseling
-
§ 3.08.03Who May Assert the Privilege
-
§ 3.08.04When to Assert the Privilege
-
§ 3.08.05Waiver of the Privilege
-
§ 3.08.06The Privilege in Federal Courts
-
§ 3.08.07Constitutionality of the Privilege
-
§ 3.08.08Child Abuse Reporting
-
§ 3.08.09Confidentiality
-
§ 3.08.10Disclosure to Civil Authorities
-
§ 3.08.11Church Records
-
§ 3.08.12Death of the Counselee
-
-
§ 3.09Visiting Privileges at Penal Institutions
-
§ 3.10Immigration of Alien Ministers, Religious Vocations, and Religious Occupations
-
§ 3.11Miscellaneous Benefits
4Liabilities, Limitations, and Restrictions
-
§ 4.01Negligence
-
§ 4.02Defamation—In General
-
§ 4.02.01Pastors Who Are Sued for Making Defamatory Statements
-
§ 4.02.02Pastors Who Are Victims of Defamation
-
§ 4.02.03Defenses
-
-
§ 4.03Undue Influence
-
§ 4.04Invasion of Privacy
-
§ 4.05Clergy Malpractice
-
§ 4.06Contract Liability
-
§ 4.07Securities Law Violations
-
§ 4.08Failure to Report Child Abuse
-
§ 4.09Diversion of Church Funds
-
§ 4.10State Regulation of Psychologists and Counselors
-
§ 4.11Sexual Misconduct
-
§ 4.11.01Theories of Liability
-
§ 4.11.02Defenses to Liability
-
5Definitions
-
§ 5.01Tax Legislation—Federal
-
§ 5.01.01Churches
-
§ 5.01.02Mail Order Churches
-
§ 5.01.03Other Religious Organizations
-
§ 5.01.04Tax Legislation—State
-
-
§ 5.02Zoning Law
-
§ 5.02.01Churches
-
§ 5.02.02Accessory Uses
-
6Organization and Administration
-
§ 6.01Unincorporated Associations
-
§ 6.01.01Characteristics
-
§ 6.01.02Personal Liability of Members
-
§ 6.01.03Creation and Administration
-
-
§ 6.02Corporations
-
§ 6.02.01The Incorporation Process
-
§ 6.02.02Charters, Constitutions, Bylaws, and Resolutions
-
-
§ 6.03Church Records
-
§ 6.03.01Inspection
-
§ 6.03.02“Accountings” of Church Funds
-
§ 6.03.03Public Inspection of Tax-Exemption Applications
-
§ 6.03.04Government Inspection of Donor and Membership Lists
-
§ 6.03.05The Church Audit Procedures Act
-
§ 6.03.06Who Owns a Church’s Accounting Records?
-
-
§ 6.04Reporting Requirements
-
§ 6.04.01State Law
-
§ 6.04.02Federal Law
-
-
§ 6.05Church Names
-
§ 6.06Officers, Directors, and Trustees—In General
-
§ 6.06.01Election or Appointment
-
§ 6.06.02Authority
-
§ 6.06.03Meetings
-
§ 6.06.04Removal
-
-
§ 6.07Officers, Directors, and Trustees—Personal Liability
-
§ 6.07.01Tort Liability
-
§ 6.07.02Contract Liability
-
§ 6.07.03Breach of the Fiduciary Duty of Care
-
§ 6.07.04Breach of the Fiduciary Duty of Loyalty
-
§ 6.07.05Violation of Trust Terms
-
§ 6.07.06Securities Law
-
§ 6.07.07Wrongful Discharge of an Employee
-
§ 6.07.08Willful Failure to Withhold Taxes
-
§ 6.07.09Exceeding the Authority of the Board
-
§ 6.07.10Loans to Directors
-
-
§ 6.08Immunity Statutes
-
§ 6.08.01Directors and Officers Insurance
-
-
§ 6.09Members—In General
-
§ 6.09.01Selection and Qualifications
-
§ 6.09.02Authority
-
-
§ 6.10Members—Discipline and Dismissal
-
§ 6.10.01Judicial Nonintervention
-
§ 6.10.02“Marginal” Civil Court Review
-
§ 6.10.03Preconditions to Civil Court Review
-
§ 6.10.04Remedies for Improper Discipline or Dismissal
-
-
§ 6.11Members—Personal Liability
-
§ 6.12Meetings of Members
-
§ 6.12.01Procedural Requirements
-
§ 6.12.02Minutes
-
§ 6.12.03Parliamentary Procedure
-
§ 6.12.04Effect of Procedural Irregularities
-
§ 6.12.05Judicial Supervision of Church Elections
-
§ 6.12.06Who May Attend
-
-
§ 6.13Powers of a Local Church
-
§ 6.14Merger and Consolidation
-
§ 6.15Dissolution
7Church Property
-
§ 7.01Church Property Disputes—In General
-
§ 7.02Church Property Disputes—Supreme Court Rulings
-
§ 7.03State and Lower Federal Court Rulings
-
§ 7.04Church Property Disputes—Dispute Resolution Procedures
-
§ 7.05Transferring Church Property
-
§ 7.06Zoning Law
-
§ 7.07Restricting Certain Activities Near Church Property
-
§ 7.08Building Codes
-
§ 7.08.01Lead Paint on Church Property
-
-
§ 7.09Nuisance
-
§ 7.10Landmarking
-
§ 7.11Eminent Domain
-
§ 7.12Defacing Church Property
-
§ 7.13Restrictive Covenants
-
§ 7.14Reversion of Church Property to the Prior Owner
-
§ 7.15Materialmen’s Liens
-
§ 7.16Religious Discrimination in the Sale or Rental of Church Property
-
§ 7.17Removing Disruptive Individuals
-
§ 7.18Adverse Possession
-
§ 7.19Accounting for Depreciation
-
§ 7.20Premises Liability
-
§ 7.20.01Liability Based on Status as Invitee, Licensee, or Trespasser
-
§ 7.20.02Defenses to Premises Liability
-
§ 7.20.03Use of Church Property by Outside Groups
-
§ 7.20.04Assaults on Church Property
-
§ 7.20.05Skate Ramps
-
§ 7.20.06Sound Rooms
-
-
§ 7.21Embezzlement
-
§ 7.22Places of Public Accommodation
8Employment Law
-
§ 8.01Introduction: Selection of Employees
-
§ 8.02New Hire Reporting
-
§ 8.03Employment Eligibility Verification
-
§ 8.04Immigration
-
§ 8.05Negligent Selection
-
§ 8.06Introduction: Compensation and Benefits
-
§ 8.07Workers Compensation
-
§ 8.08Fair Labor Standards Act
-
§ 8.08.01Enterprises
-
§ 8.08.02Individual Coverage
-
§ 8.08.03Federal Court Rulings
-
§ 8.08.04Department of Labor Opinion Letters
-
§ 8.08.05Exemptions
-
§ 8.08.06Ministers
-
§ 8.08.07State Laws
-
§ 8.08.08Case Studies
-
-
§ 8.09Introduction to Federal Employment and Civil Rights Laws—The “Commerce” Requirement
-
§ 8.09.01Counting Employees
-
-
§ 8.10The “Ministerial Exception” under State and Federal Employment Laws
-
§ 8.11Procedure for Establishing a Discrimination Claim
-
§ 8.12Title VII of the Civil Rights Act of 1964
-
§ 8.12.01Application to Religious Organizations
-
§ 8.12.02Application to Religious Educational Institutions
-
§ 8.12.03Religion as a "Bona Fide Occupational Qualification"
-
§ 8.12.04Discrimination Based on Religion or Morals
-
§ 8.12.05Sexual Harassment
-
§ 8.12.06The Catholic Bishop Case
-
§ 8.12.07Failure to Accommodate Employees’ Religious Practices
-
§ 8.12.08The Religious Freedom Restoration Act
-
§ 8.12.09The Civil Rights Act of 1991
-
-
§ 8.13The Age Discrimination in Employment Act
-
§ 8.14The Americans with Disabilities Act
-
§ 8.14.01Discrimination in Employment
-
§ 8.14.02Discrimination in Public Accommodations
-
-
§ 8.15Family and Medical Leave Act
-
§ 8.16Employer “Retaliation” Against Victims of Discrimination
-
§ 8.17Discrimination Based on Military Status
-
§ 8.18Employee Polygraph Protection Act
-
§ 8.19Occupational Safety and Health Act
-
§ 8.20Display of Posters
-
§ 8.21Discrimination under State Laws
-
§ 8.22Termination of Employees
-
§ 8.22.01Severance Agreements
-
-
§ 8.23National Labor Relations Act
-
§ 8.24Reference Letters
-
§ 8.25Employee Evaluations
-
§ 8.26Employment Interviews
-
§ 8.27Arbitration
-
§ 8.28Employee Handbooks
-
§ 8.29Employee Privacy
-
§ 8.30Insurance
9Government Regulation of Churches
-
§ 9.01Introduction
-
§ 9.02Regulation of Charitable Solicitations
-
§ 9.03Limitations on Charitable Giving
-
§ 9.04Federal and State Securities Law
-
§ 9.05Copyright Law
-
§ 9.05.01Copyright Ownership
-
§ 9.05.02Works Made for Hire
-
§ 9.05.03Exclusive Rights
-
§ 9.05.04Infringement
-
§ 9.05.05The "Religious Service" Exemption to Copyright Infringement
-
§ 9.05.06Electronic Media
-
§ 9.05.10Other Exceptions to Copyright Infringement
-
-
§ 9.06Government Investigations
-
§ 9.07Judicial Resolution of Church Disputes
-
§ 9.08Political Activities by Churches and Other Religious Organizations
-
§ 9.09Bankruptcy Law
10Church Legal Liability
-
§ 10.01Negligence as a Basis for Liability—In General
-
§ 10.02Vicarious Liability (Respondeat Superior)
-
§ 10.02.01The Requirement of Employee Status
-
§ 10.02.02Negligent Conduct
-
§ 10.02.03Course of Employment
-
§ 10.02.04Inapplicability to Nonprofit Organizations
-
-
§ 10.03Negligent Selection of Church Workers—In General
-
§ 10.04Negligent Selection of Church Workers—Sexual Misconduct Cases Involving Minor Victims
-
§ 10.05Negligent Selection of Church Workers—Sexual Misconduct Cases Involving Adult Victims
-
§ 10.05.01Court Decisions Recognizing Negligent Selection Claims
-
§ 10.05.02Court Decisions Rejecting Negligent Selection Claims
-
§ 10.05.03Risk Management
-
-
§ 10.06Negligent Selection of Church Workers—Other Cases
-
§ 10.07Negligent Retention of Church Workers—In General
-
§ 10.07.01Court Decisions Recognizing Negligent Retention Claims
-
§ 10.07.02Court Decisions Rejecting Negligent Retention Claims
-
§ 10.07.03Risk Management
-
-
§ 10.08Negligent Supervision of Church Workers—In General
-
§ 10.09Negligent Supervision of Church Workers—Sexual Misconduct Cases Involving Minor Victims
-
§ 10.09.01Court Decisions Recognizing Negligent Supervision Claims
-
§ 10.09.02Court Decisions Rejecting Negligent Supervision Claims
-
§ 10.09.03Risk Management
-
-
§ 10.10Negligent Supervision of Church Workers—Sexual Misconduct Cases Involving Adult Victims
-
§ 10.10.01Court Decisions Recognizing Negligent Supervision Claims
-
§ 10.10.02Court Decisions Rejecting Negligent Supervision Claims
-
§ 10.10.03Risk Management
-
-
§ 10.11Negligent Supervision of Church Workers—Other Cases
-
§ 10.11.01Risk Management
-
-
§ 10.12Counseling—In General
-
§ 10.12.01Risk Management
-
-
§ 10.13Breach of a Fiduciary Duty
-
§ 10.13.01Court Decisions Recognizing Fiduciary Duty Claims
-
§ 10.13.02Court Decisions Rejecting Fiduciary Duty Claims
-
§ 10.13.03Risk Management
-
-
§ 10.14Ratification
-
§ 10.15Defamation
-
§ 10.16Defenses to Liability
-
§ 10.16.01Contributory and Comparative Negligence
-
§ 10.16.02Assumption of Risk
-
§ 10.16.03Intervening Cause
-
§ 10.16.04Statutes of Limitations
-
§ 10.16.05Charitable Immunity
-
§ 10.16.06Release Forms
-
§ 10.16.07Insurance
-
§ 10.16.08Other Defenses
-
-
§ 10.17Damages—In General
-
§ 10.17.01Punitive Damages
-
§ 10.17.02Duplicate Verdicts
-
-
§ 10.18Denominational Liability—In General
-
§ 10.18.01Court Decisions Recognizing Vicarious Liability
-
§ 10.18.02Court Decisions Rejecting Vicarious Liability
-
§ 10.18.03Defenses to Liability
-
§ 10.18.04Risk Management
-
§ 10.18.05The Legal Effect of a Group Exemption Ruling
-
-
§ 10.19Risks Associated with Cell Phones
-
§ 10.20Risks Associated with the Use of 15-Passenger Vans
12The Present Meaning of the First Amendment Religion Clauses
-
§ 12.01The Establishment Clause
-
§ 12.01.01The Lemon Test
-
-
§ 12.02The Free Exercise Clause
-
§ 12.02.01The Smith Case
-
§ 12.02.02The Religious Freedom Restoration Act
-
§ 12.02.03The City of Boerne Case
-
§ 12.02.04Conclusions
-
13Significant First Amendment Issues
-
§ 13.01The Right to Witness
-
§ 13.02Prayer on Public Property other than Schools
-
§ 13.03Prayer During Public School Activities
-
§ 13.04Display of Religious Symbols on Public Property
-
§ 13.05Recurring Use of Public Property by Religious Congregations for Religious Services
-
§ 13.06Nonrecurring Use of Public Property by Adults for Religious Events and Activities
-
§ 13.07Use of Public School Property by Students for Religious Purposes
-
§ 13.08Sunday Closing Laws
-
§ 13.09The Right to Refuse Medical Treatment
-
§ 13.10Definition of "Religion" and "Religious"
This content is designed to provide accurate and authoritative information in regard to the subject matter covered. It is sold with the understanding that the publisher is not engaged in rendering legal, accounting, or other professional service. If legal advice or other expert assistance is required, the services of a competent professional person should be sought. "From a Declaration of Principles jointly adopted by a Committee of the American Bar Association and a Committee of Publishers and Associations." Due to the nature of the U.S. legal system, laws and regulations constantly change. The editors encourage readers to carefully search the site for all content related to the topic of interest and consult qualified local counsel to verify the status of specific statutes, laws, regulations, and precedential court holdings.
-