Williams v. Kingdom Hall, 2019 UT App 40 (March 21, 2019)

The plaintiff sued her church for negligent and intentional infliction of emotional distress after she was subjected to church disciplinary proceedings and forced to listen to an audio recording of her being raped by another church member for several hours, while church leaders questioned whether she consented to various acts on the tape.  The Court of Appeals affirmed the district court’s dismissal of these claims under the Establishment Clause of the First Amendment, because they would require inquiry into the appropriateness of the church’s conduct in applying a religious practice.