In Gaddy v. The Corporation of the President of the Church of Jesus Christ of Latter-Day Saints, (10th Cir., Aug. 26, 2025), the U.S. 10th Circuit Court of Appeals affirmed the dismissal of a RICO suit against the Latter-Day Saints Church. Plaintiffs, who for many years had made tithing payments to the Church, contended that the Church had made misrepresentations about the Church's history and origins. The court said in part:
On their fraudulent misrepresentations RICO theory, Plaintiffs make several attacks on the factual accuracy of what the Church teaches its members. Plaintiffs claim that key historical events for the religion occurred differently than how the Church describes them canonically. Allegedly, by preaching false statements about its own history, the Church engaged in a “pattern of racketeering.” ... Had Plaintiffs known of these alleged misrepresentations, they say, they would not have committed to the Church....
We conclude that the church autonomy doctrine applies to Plaintiffs’ allegations about the Church’s alleged misrepresentations and omissions about its history, because the dispute about the accuracy of the Church’s representations is ecclesiastical, not “purely secular.” ... Plaintiffs’ allegations require a court to dive into deeply religious waters to assess whether foundational events for a religion occurred the way the religion teaches....
Plaintiffs’ second RICO theory [is] ... fraudulent misuse of tithing funds.... We conclude that Plaintiffs have failed to plead sufficient facts to support a reasonable inference of causation between any of the challenged misrepresentations or omissions by the Church about how it would use tithing payments and the alleged harm Plaintiffs suffered.... As a result, we need not decide whether the church autonomy doctrine precludes the adjudication of this theory....
Judge Phillips filed a concurring opinion, saying in part:
I write separately because I would also decide that the church autonomy doctrine does not apply to Plaintiffs’ second civil RICO theory—that the Church fraudulently used tithing payments for commercial purposes.... [I]t “does not apply to purely secular decisions, even when made by churches.”
Deseret News reports on the decision.
