Plaintiff Laura Gaddy was a member of The Church of Jesus Christ of Latter-day Saints most of her life before she left. She then sued, alleging the Church had intentionally misrepresented its foundational history to induce faith in the Church and its teachings. The Church argued the Free Exercise and Establishment Clauses of the First Amendment (the Religion Clauses) foreclose Gaddy’s lawsuit because her claims implicated the Church’s fundamental religious beliefs.
The United States District Court for the District of Utah granted the Church’s motion to dismiss on First Amendment grounds, concluding, “Churches can be liable for fraud claims like anyone else. But the First Amendment bars such claims when they would require a court to consider the truth or falsity of a church’s religious doctrines. … [T]he Church is no more liable for preaching and teaching its beliefs than it is for espousing them.”