In
Mansfield v. Horner, (MO App., June 17, 2014), a Missouri state appellate court upheld a wrongful death judgment of over $108 million in the faith-healing death of Misty Mansfield growing out of complications after the stillbirth of her child. The suit was brought by Misty's parents against her husband Caleb Horner and Caleb's brother, John, who was the leader of the faith-healing sect to which Caleb and Misty belonged. The sect, which Misty joined only when she married Caleb, also required a wife to be submissive to their husband's decisions. Caleb convinced Misty not to go to the hospital when complications arose during her labor at home, and the breech delivery was botched by Caleb and his religious-based birth team. Caleb's brother John arrived after the stillbirth and prayed for hours attempting to raise the child from the dead, while Misty was not treated for her vaginal cuts and an emergency team that arrived 9 hours later was denied access to Misty by Caleb. A month after the delivery, Misty died from an ongoing infection.
The appeals court rejected nine objections to the trial court's refusal to override the jury's verdict, including an objection that the suit violates the First Amendment's free exercise clause. Rejecting that argument, the court said in part:
None of [the jury] instructions required the jury to determine the validity of the Horners' belief in faith healing. The jury never had to determine "the truth or falsity" of faith healing. Instead, the instructions required the jury to determine whether or not the Horners' actions -- particularly with respect to Caleb's actions during the home birth and John and Caleb's actions preventing Misty from seeking medical treatment following the home birth -- constituted negligence. Thus, we do not conclude that the trial court committed plain error in overruling the Horners' motion for JNOV with respect to their claim of a First Amendment violation.
