Meroni v. Holy Spirit Association (1986)

While this case is from an intermediate appellate court, it requires special emphasis. The case was a tort action against the church by the father of a former church member who had committed suicide. The father blamed the suicide on allegations of mind control, brainwashing and various non-violent church practices. The court rejected the claims as a matter of law, holding that the Free Exercise Clause protects the church and prospective members from liability for peaceful, if rigorous, religious practices. The court held:

“[An individual] must have the personal and individual right to determine for himself or herself to associate with a religious group. … Otherwise, in order to avoid potential liability, neither the Church nor any other association could ever rely on a person’s agreement to join, and the individual’s ability to consent to join would be severely compromised.”