REVEALING SIN FROM THE PULPIT

Setting aside for this report the idea that revealing a member’s sin from the pulpit might be insensitive or even cruel, the question presented is whether it is actionable in a lawsuit.  For non-church entities like businesses and government, unless there is a duty to speak, and even if truth was a valid defense, the conduct might still be sufficiently outrageous to constitute a Tort of Outrage claim, in those states that have such claims.

In Hullibarger v Archdiocese of Detroit, Slip Op. (Mich. App. 2021) the Plaintiff’s child committed suicide.  (The opinion does not disclose whether the child was an adult or a minor.)  The family did not disclose this outside of the family and a few close friends.  Somehow, the priest learned of it and at the funeral service revealed it during the homily.  The priest proceeded to “preach about suicide as a grave sin and specifically how it endangered the immortal soul of the plaintiff’s son.”  The Plaintiff complained to the Archbishop but the Archbishop would not grant an audience.  The Plaintiff sued alleging infliction of emotional distress, misrepresentation, invasion of privacy and claims against the church for negligent supervision.  The trial court dismissed the case under the Ecclesiastical Abstention Doctrine.  The appellate court affirmed.

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