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Pastor Who Revealed Child’s Suicide During a Funeral Sermon Can’t Be Sued

Court: Ecclesiastical abstention doctrine bars lawsuit from the mother of deceased son.

Key point 4-04. Many states recognize “invasion of privacy” as a basis for liability. Invasion of privacy may consist of any one or more the following: (1) public disclosure of private facts; (2) use of another person’s name or likeness; (3) placing someone in a “false light” in the public eye; or (4) intruding upon another’s seclusion.

A Michigan appellate court affirmed a lower court’s ruling that the mother (the “plaintiff”) of a suicide victim was barred by the ecclesiastical abstention doctrine from suing a pastor who, contrary to her insistence upon confidentiality, still disclosed the suicide during the victim’s funeral homily.


In early December 2018, a young man committed suicide. This fact was not publicly disclosed or known to anyone but close family and friends.

The day after their son’s death, the decedent’s ...

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  • May 6, 2022

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