Williams v. Kingdom Hall, 2021 UT 18 (June 3, 2021)

On certiorari, the Utah Supreme Court vacated the district court’s dismissal of an intentional infliction of emotional distress claim which was based on the manner in which Elders of the Kingdom Hall Jehovah’s Witnesses conducted a disciplinary proceeding. The district court had applied the test established in Lemon v. Kurtzman to hold that the IIED claim would violate the Establishment Clause. The supreme court remanded and instructed the district court to take into account the United States Supreme Court’s recent departure from Lemon and application of a “more modest approach” under which courts “should eschew a rigid formula in evaluating Establishment Clause cases.”