325 F. Supp. 3d 1198
D.N.M.2018Background
- Plaintiff (VA) joined JMGC/Companions of Wisdom, an invitation-only Vermont nonprofit led by Kenneth and Deborah Alexander, beginning in 2008 and attended conferences including one in Santa Fe, NM where the disputed communications occurred.
- JMGC promotes reincarnation-based doctrines conveyed via channeled communications, seminars, writings, and enforces strict internal conformity; Mr. Alexander is alleged to be the spiritual leader who channels binding instructions.
- Plaintiff questioned leadership and refused to follow a directive to lie on a government security-clearance form; in retaliation JMGC published statements at a Santa Fe conference and online accusing aspects of Plaintiff’s "soul" of sexual and financial predation and linking her to sex cults.
- Plaintiff sued in New Mexico state law torts (defamation, false light, intentional infliction of emotional distress, civil conspiracy) and sought injunctive relief; Defendants moved to dismiss under Rule 12(b)(6) invoking the First Amendment church-autonomy doctrine.
- The court treated the church-autonomy doctrine as an affirmative defense addressable on a 12(b)(6) motion and found the complaint’s allegations showed JMGC’s beliefs and practices are “religious” for First Amendment purposes.
- Holding: plaintiff’s tort claims were barred because adjudication would require resolving religious doctrine, membership discipline, and shunning—areas protected by the church-autonomy/free‑exercise principles—so the complaint was dismissed with prejudice.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether JMGC's beliefs are "religious" under the First Amendment | Plaintiff did not plead JMGC is a religion and disputes that channeled communications are religious | JMGC's metaphysical doctrines, channeled communications, rituals, writings, conferences, hierarchy, and discipline show indicia of religion | Court: Allegations establish religion for First Amendment purposes |
| Whether the church‑autonomy doctrine bars plaintiff's tort claims | Plaintiff: claims are secular torts resolvable by neutral principles | Defendants: claims arise from internal ecclesiastical matters (doctrine, discipline, membership) and are barred | Court: Claims are rooted in religious belief/discipline and barred |
| Whether tort adjudication could proceed under neutral principles without doctrinal entanglement | Plaintiff: neutral tort principles apply; no doctrinal resolution needed | Defendants: truth/falsity and motive of channeled statements implicate theological beliefs and membership decisions | Court: Resolution would require determining religious truths/discipline—impermissible entanglement |
| Whether publication to membership (and website) defeats First Amendment shield | Plaintiff: publication caused reputational harm and broader dissemination; thus torts actionable | Defendants: statements were part of internal disciplinary process and shunning; publication to members invokes autonomy | Court: Publication in context of membership discipline/shunning strengthens First Amendment bar; claims dismissed |
Key Cases Cited
- Watson v. Jones, 80 U.S. 679 (establishes older common‑law principle that secular courts must abstain from "strictly and purely ecclesiastical" matters)
- Milivojevich v. Serbian E. Orthodox Diocese, 426 U.S. 696 (U.S. Supreme Court reaffirming judicial noninterference in ecclesiastical disputes)
- Kedroff v. St. Nicholas Cathedral, 344 U.S. 94 (recognizes First Amendment grounding for religious organizations' independence)
- Hosanna‑Tabor Evangelical Lutheran Church & School v. EEOC, 565 U.S. 171 (ministerial exception is an affirmative defense grounded in the First Amendment)
- Paul v. Watchtower Bible & Tract Soc., 819 F.2d 875 (9th Cir.) (First Amendment bars tort claims based on religious practice of shunning)
- Bryce v. Episcopal Church in the Diocese of Colo., 289 F.3d 648 (10th Cir.) (discusses church‑autonomy as a defense and circuit split over procedural posture)
- Ashcroft v. Iqbal, 556 U.S. 662 (pleading standards for plausibility on a 12(b)(6) motion)
- Bell Atlantic Corp. v. Twombly, 550 U.S. 544 (Twombly pleading requirements)
- United States v. Meyers, 906 F. Supp. 1494 (D. Wyo.) (factors for assessing whether a set of beliefs qualifies as "religious")