Case suggests that the RFRA may also serve as an alternative basis, in addition to clergy-penitent privilege laws, for protecting confidential communications with clergy from involuntary disclosure.
Inculpatory statements made by a murder suspect to a church employee were not protected from disclosure by the clergy-penitent privilege because the employee was not a minister and the privilege had been waived.
First Amendment religion clauses prevented the civil courts from resolving a parishioner's claim that a priest improperly disclosed his confidential communications without permission.