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Ryan Koster v. Harvest Bible Chapel-Quad Cities, et al. IA Church Dispute Litigation
The plaintiff and his wife were members of the defendant church, and participated in a small group of which the pastor was a member. The plaintiff and his wife eventually divorced, based in part upon an allegation that the plaintiff had abused their daughter. A temporary restraining order was issued, but the charges were eventually determined to be unfounded. The plaintiff was ultimately granted custody in the divorce case, after the divorce court found that the wife was not credible.
While the divorce was pending, the pastor made various communications with other church members. The plaintiff contended that these were defamatory, and violated the fiduciary duties the pastor owed to the plaintiff. The district court, Scott County, Iowa, dismissed the claims and the plaintiff appealed. The case was ultimately heard by the Iowa Supreme Court, which affirmed.
The high court noted that under Serbian E. Orthodox Diocese for the U.S. & Can. v. Milivojevich, 426 U.S. 696 (1976), such church disputes must be decided under neutral principles of law. The court characterized the case as "essentially involv[ing] an allegation that a church bungled a response to a disturbing episode, thereby causing significant emotional harm to a parishioner." The deciding factor, according to the court, was "whether we can say 'the purportedly tortious conduct was not grounded in any religious belief or practice,' or to put it another way, whether the liability determination 'would treat religious and nonreligious entities equally.'"
The court held that any duties owed to the plaintiff were, in fact, grounded in religious belief or practice. To put it another way, the disposition of the case involved more than a secular standard of conduct.
The court also held that the defamation case was barred by the pastor's qualified privilege.
For these reasons, the Supreme Court affirmed the district court's judgment.
No. 20-0236 (Iowa May 21, 2021).
Please see the original opinion for the court's exact language.
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Richard P. Clem is an attorney and continuing legal education (CLE) provider in Minnesota. He has been in private practice in the Twin Cities for 25 years. He has a J.D., cum laude, from Hamline University School of Law in St. Paul and a B.A. in History from the University of Minnesota. His reported cases include: Asociacion Nacional de Pescadores a Pequena Escala o Artesanales de Colombia v. Dow Quimica de Colombia, 988 F.2d 559, rehearing denied, 5 F.3d 530 (5th Cir. 1993), cert. denied, 510 U.S. 1041 (1994); LaMott v. Apple Valley Health Care Center, 465 N.W.2d 585 (Minn. Ct. App. 1991); Abo el Ela v. State, 468 N.W.2d 580 (Minn. Ct. App. 1991).
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