Objective coverage of church-state and religious liberty developments, with extensive links to primary sources.
Wednesday, January 21, 2015
Supreme Court Hears Arguments In Fair Housing Act Disparate-Impact Case
The U.S. Supreme Court heard oral arguments today in Texas Department of Housing and Community Affairs v. Inclusive Communities Project, Inc. At issue in the case is whether disparate-impact claims are cognizable under the Fair Housing Act, or whether there must be a showing of intentional discrimination. While this case involves claims of racially discriminatory impact, the Court's decision will apply to cases involving religious discrimination as well. The transcript of full oral arguments is available from the Supreme Court's website. SCOTUSblog's case page contains links to all the briefs in the case as well as to the 5th Circuit's decision below. SCOTUSblog also reports on today's arguments.
Labels:
Fair Housing Act,
US Supreme Court
Cert. Denied In Dispute Over Characterization of Communications With Priest
The U.S. Supreme Court yesterday denied certiorari in Roman Catholic Church of the Diocese of Baton Rouge v. Mayeux, (Docket No. 14-220, cert. denied 1/20/2015) (Order List). In the case, the Louisiana Supreme Court held that a trial court could decide whether a communication between a teenager and a priest over the 14-year old's romantic relationship with a parishioner amounted to a confession regardless of the Church's characterization of the communication. (See prior posting.) The Baton Rouge Advocate reports on the denial of review.
Labels:
Catholic,
Louisiana,
Sex abuse claims
Tuesday, January 20, 2015
Some Thoughts On Today's Supreme Court Decision In Holt v. Hobbs
Today's Supreme Court decision in Holt v. Hobbs (see prior posting) is likely to lead to a dramatic increase in resources that federal district courts must devote to the dozens-- if not hundreds-- of prisoner RLUIPA cases that are filed each year. Federal courts, under 28 USC Sec. 1915A, are required to conduct an early preliminary screening of prisoner lawsuits in order to dismiss those that have no chance of success. It has been common for district courts to dismiss cases at this preliminary stage on the ground that the inmate has failed to show a "substantial burden" on his or her religious exercise. Often courts have reached that conclusion on the basis that, while an inmate was denied the ability to carry out some particular religious ritual or requirement, the inmate had a number of other ways to practice his or her faith. Today the Supreme Court rejected that approach, saying:
Finally one additional portion of the Court's opinion adds complexity to the question of when a religious exemption from a prison rule must be granted. The Court said:
[T]he District Court erred by concluding that the grooming policy did not substantially burden petitioner’s religious exercise because “he had been provided a prayer rug and a list of distributors of Islamic material, he was allowed to correspond with a religious advisor, and was allowed to maintain the required diet and observe religious holidays.”... In taking this approach, the District Court improperly imported a strand of reasoning from cases involving prisoners’ First Amendment rights. See, e.g., O’Lone v. Estate of Shabazz, 482 U. S. 342, 351–352 (1987); see also Turner v. Safley, 482 U. S. 78, 90 (1987). Under those cases, the availability of alternative means of practicing religion is a relevant consideration, but RLUIPA provides greater protection. RLUIPA’s “substantial burden” inquiry asks whether the government has substantially burdened religious exercise (here, the growing of a 1⁄2-inch beard), not whether the RLUIPA claimant is able to engage in other forms of religious exercise.So courts will now need to concentrate on the "compelling interest" and "least restrictive means" prongs of RLUIPA in initial screening of complaints. More cases are likely to survive initial screening when those elements are the focus. In prison contexts, generally one of two sorts of compelling interests are asserted-- (1) prison security or (2) budgetary concerns in accommodating prisoner religious practices. In Holt, security and safety were asserted, and the Court conceded that those are compelling interests. However it suggested that budgetary concerns (such as those asserted when inmates seek religious diets) pose a more difficult question, saying:
Congress stated that RLUIPA “may require a government to incur expenses in its own operations to avoid imposing a substantial burden on religious exercise.” §2000cc–3(c). See Hobby Lobby....When it comes to evaluating whether the government has shown that its restriction on religious exercise is the least restrictive means of furthering a compelling governmental interest, the Court emphasized that the inquiry must be narrowly focused:
The Department argues that its grooming policy represents the least restrictive means of furthering a “‘broadly formulated interes[t],’” ... namely, the Department’s compelling interest in prison safety and security. But RLUIPA, like RFRA, contemplates a “‘more focused’” inquiry and “‘requires the Government to demonstrate that the compelling interest test is satisfied through application of the challenged law “to the person”––the particular claimant whose sincere exercise of religion is being substantially burdened.’”... RLUIPA requires us to “‘scrutiniz[e] the asserted harm of granting specific exemptions to particular religious claimants’” and “to look to the marginal interest in enforcing” the challenged government action in that particular context....How far must this individualization go? Must authorities consider how likely it is that the particular claimant will create a security risk? Should the evaluation of alternatives depend, for example, on whether the particular inmate seeking to grow a beard has a history of attempting to smuggle contraband? The more individualized the determination must be, the fewer cases that will be able to be disposed of at the preliminary screening stage.
Finally one additional portion of the Court's opinion adds complexity to the question of when a religious exemption from a prison rule must be granted. The Court said:
[T]he District Court went astray when it relied on petitioner’s testimony that not all Muslims believe that men must grow beards. Petitioner’s belief is by no means idiosyncratic.... But even if it were, the protection of RLUIPA, no less than the guarantee of the Free Exercise Clause, is “not limited to beliefs which are shared by all of the members of a religious sect.”Those who follow Religion Clause's weekly summary of prisoner free exercise cases know that inmates professing a wide variety of religious beliefs seek religious accommodations relating to grooming, clothing, possession of religious items, worship space, congregate religious services, religious dietary restrictions, and more. The Supreme Court has now reaffirmed the conclusion of most courts that an inmate may invoke RLUIPA to require accommodation of a totally idiosyncratic belief-- so long as it is sincerely held. Religious visions shared by no one else apparently still qualify.
Labels:
Prisoner cases,
RLUIPA,
US Supreme Court
Supreme Court Unanimously Upholds Muslim Inmate's Right To Grow Half-Inch Beard
Today in Holt v. Hobbs, (Sup. Ct., Jan 20, 2015), the U.S. Supreme Court unanimously held that the Arkansas Department of Corrections policy that prevents a Muslim inmate from growing a one-half inch beard for religious reasons violates the Religious Land Use and Institutionalized Persons Act. In an opinion by Justice Alito the court held that it is irrelevant for purposes of RLUIPA that an inmate has other means of practicing his religion. While cases invovling prisoners' First Amendment rights invoke that reasoning, RLUIPA provides greater protection. The court went on to reject the state's contention that its no-beard policy is the least restictive means of furthering a compelling state interest. It found unpersuasive the state's arguments regarding contraband and identification of inmates. The Court added that prison officials still have ample ways to maintain security, saying that "in applying RLUIPA’s statutory standard, courts should not blind themselves to the fact that the analysis is conducted in the prison setting."
Justice Ginsburg filed a short concurring opinion, joined by Justice Sotomayor, emphasizing that here, unlike in the Hobby Lobby case, accommodating petitioner's religious beliefs would not detrimentally affect third parties who do not share his beliefs. Justice Sotomayor filed a separate concurring opinion saying: "I do not understand the Court’s opinion to preclude deferring to prison officials’ reasoning when that deference is due—that is, when prison officials offer a plausible explanation for their chosen policy that is supported by whatever evidence is reasonably available to them."
Justice Ginsburg filed a short concurring opinion, joined by Justice Sotomayor, emphasizing that here, unlike in the Hobby Lobby case, accommodating petitioner's religious beliefs would not detrimentally affect third parties who do not share his beliefs. Justice Sotomayor filed a separate concurring opinion saying: "I do not understand the Court’s opinion to preclude deferring to prison officials’ reasoning when that deference is due—that is, when prison officials offer a plausible explanation for their chosen policy that is supported by whatever evidence is reasonably available to them."
Labels:
RLUIPA,
Supreme Court
Indiana County Fights Creche Suit By Enacting Open Forum Law
The Batesville (IN) Herald-Tribune reports that last week the Franklin County, Indiana Commissioners passed Ordinance 2015-02 to create a public forum on the county courthouse grounds permitting displays, demonstrations, exhibits, rallies and other expressive activities without regard to viewpoint under a neutral permit process. The action was taken in response to a lawsuit filed against the county last month challenging the constitutionality of a life size Nativity Scene displayed on the courthouse lawn. (See prior posting.)
UPDATE: According to WLWT, on Feb. 10 plaintiffs dropped the lawsuit.
UPDATE: According to WLWT, on Feb. 10 plaintiffs dropped the lawsuit.
St. Paul-Minneapolis Archdiocese Files For Bankruptcy Reorganization
On Friday, the Catholic Archdiocese of Saint Paul and Minneapolis filed for Chapter 11 Bankruptcy Reorganization. In a letter (full text) announcing the decision, Archbishop John Nienstedt said it "will allow the finite resources of the Archdiocese to be distributed equitably among all victims/ survivors [of clergy sexual abuse]. It will also permit the Archdiocese to provide essential services required to continue its mission within this 12-county district." The Archdiocese has posted the full text of the Voluntary Petition and other legal and financial documents in the case. Reporting on the filing, MPR News points out that it will stop civil trials that were set to begin on Jan. 26.
Labels:
Bankruptcy,
Catholic
More Preliminary Details of Pope's September U.S. Visit Emerge
Preliminary details of Pope Francis' itinerary during his September visit to the United States are becoming known. From a report by CBS/AP on the Pope's news conference yesterday and a report by the Washington Times on details disclosed by Archbishop Bernardito Auza, the Pontiff's likely schedule so far looks like this:
Washington D.C. Sept. 22-24:
New York- Sept. 24-26
Philadelphia (World Meeting of Families)- Sept. 26-27
Washington D.C. Sept. 22-24:
- Arrival- evening of Sept. 22
- Welcoming ceremony at White House- morning of Sept. 23
- Mass at Basilica of the National Shrine of the Immaculate Conception (for bishops, consecrated and religious men and women, seminarians and representatives from humanitarian and Catholic charitable organizations). At the Mass, the Pope will canonize 17th-century founder of the first Missions in California, Junipero Serra- later on Sept. 23
- Address to Joint Session of Congress- Sept. 23 or 24
- Leave for New York-afternoon of Sept. 24
New York- Sept. 24-26
- Address to United Nations General Assembly (including opening of Post-2015 Sustainable Development Summit, with many heads of state attending)- morning of Sept. 25
- Mass in Madison Square Garden
- Visit to Ground Zero Memorial
- Visit to St. Patrick's Cathedral
- Inter-ethnic meeting
- Leave for Philadelphia- early morning of Sept. 26
Philadelphia (World Meeting of Families)- Sept. 26-27
- Prayer Vigil- Sept. 26
- Visit to a children's hospital or juvenile prison
- Mass- Sept. 27
- Depart for Rome- evening of Sept. 27
Even with this ambitious schedule, there were things that had to be omitted. The Pope said he would have liked to enter the U.S. through the Mexican border "as a sign of brotehrhood and help to the immigrants." But, he joked: ..."going to Mexico without going to visit the Madonna (of Guadalupe) would be a drama. A war could break out!"
Labels:
Pope Francis
Monday, January 19, 2015
Employee Who Objected To Biometric Scanning As Mark of the Beast Wins $150,000 Verdict
The Clarksburg Exponent Telegram reports that a jury in a West Virginia federal district court last Thursday awarded $150,000 in compensatory damages to a former employee of Consol Energy (the mining operation of Consolidation Coal Co.) in a Title VII suit charging failure to accommodate his Evangelical Christian religious beliefs. Beverly R. Butcher Jr., a laborer at the mine, objected to biometric hand scanning to track time and attendance, believing that it involves the Mark of the Beast forbidden in the Book of Revelation. The company however relied on a letter from the manufacturer of the hand scanner assuring that it does not assign the Mark of the Beast, and suggesting that objecting employees scan their left, instead of their right, hand. The company refused other accommodations suggested by Butcher, and the EEOC sued on his behalf. (See prior posting.) In addition to the jury's damage award, the judge will still determine back and forward pay. Defendants plan an appeal.
UPDATE: The 4th Circuit affirmed the district court's award of damages in U.S. Equal employment Opportunity Commission v. Consol Energy, Inc., (4th Cir., June 12, 2017).
UPDATE: The 4th Circuit affirmed the district court's award of damages in U.S. Equal employment Opportunity Commission v. Consol Energy, Inc., (4th Cir., June 12, 2017).
Labels:
Reasonable accommodation,
Title VII
Today Is Martin Luther King, Jr. Day
Today is Martin Luther King, Jr. Day, celebrating the birthday of the famous civil rights leader. This year is the 50th anniversary of the Selma to Montgomery March and of the resulting 1965 Voting Rights Act. Dr. King was, of course, a Christian minister as well as a civil right leader. His 1963 Letter From A Birmingham Jail addressed fellow clergy who criticized his tactics and set out his vision of the role of churches in influencing public policy, saying in part:
I have traveled the length and breadth of Alabama, Mississippi and all the other southern states. On sweltering summer days and crisp autumn mornings I have looked at the South's beautiful churches with their lofty spires pointing heavenward. I have beheld the impressive outlines of her massive religious education buildings. Over and over I have found myself asking: "What kind of people worship here? Who is their God? Where were their voices when the lips of Governor Barnett dripped with words of interposition and nullification? Where were they when Governor Wallace gave a clarion call for defiance and hatred?...
There was a time when the church was very powerful--in the time when the early Christians rejoiced at being deemed worthy to suffer for what they believed. In those days the church was not merely a thermometer that recorded the ideas and principles of popular opinion; it was a thermostat that transformed the mores of society.... By their effort and example they brought an end to such ancient evils as infanticide and gladiatorial contests. Things are different now. So often the contemporary church is a weak, ineffectual voice with an uncertain sound. So often it is an archdefender of the status quo. Far from being disturbed by the presence of the church, the power structure of the average community is consoled by the church's silent--and often even vocal--sanction of things as they are.
Labels:
Martin Luther King Jr.
Recent Articles of Interest
From SSRN:
- Marie Wicks, Prayer is Prologue: The Impact of Town of Greece on the Constitutionality of Deliberative Public Body Prayer at the Start of School Board Meetings, (January 9, 2015).
- Michael M. Karayanni, Groups in Context: An Ontology of a Muslim Headscarf in a Nazareth Catholic School and a Sephardic Ultra-Orthodox Student in Immanuel, (January 12, 2015).
- P.G. Monateri, Diaspora, the West and the Law. The Birth of Christian Literature Through the Letters of Paul and the End of Diaspora, (January 16, 2015).
- Richard W. Garnett, Chief Justice Rehnquist, Religious Freedom, and the Constitution, (Bradford P. Wilson, ed., The Constitutional Legacy of William H. Rehnquist (West Academic Press, 2015 Forthcoming)).
- Nathan B. Oman, International Legal Experience and the Mormon Theology of the State, 1945-2012, (Iowa Law Review, Vol. 100, 2015).
- Rebecca Gould, Ijtihād Against Madhhab: Legal Hybridity and the Meanings of Modernity in Early Modern Daghestan, (Comparative Studies in Society and History 57(1): 35-66 (2015)).
- Karen Busby & Sara Mahboob, Influences on Young Muslim Women in Winnipeg: Preliminary Report on Key Informant Interviews, (December 9, 2014).
- Mohamed A. Arafa, Whither Egypt? Against Religious Fascism and Legal Authoritarianism: Pure Revolution, Popular Coup, or a Military Coup D’État?, (Indiana International & Comparative Law Review, Vol. 24, No. 4, 2014).
- Sharifah Zubaidah Abdul Kader, The Legal Framework of Waqf in Malaysia,(January 9, 2015).
- Ujala Akram, Freedom of Speech, Freedom of Religion And Islam, (European Journal of Law Reform 2014 (6) 2).
- Armaram Shelke, Revisiting ‘The Muslim Women (Protection of Rights on Divorce) Act, 1986’ in the Light of its Impact Over Legal and Jurisprudential Principles, (Symbiosis Contemporary Law Journal (SCLJ), 2013, Volume-II, Number 1).
- Farinaz Zamani & Paula Gerber, Burqa: Human Right or Human Wrong?, ((2014) 39(4) Alternative Law Journal 231).
- Ahmed E. Souaiaia, Theories and Practices of Islamic Finance and Exchange Laws: Poverty of Interest, (International Journal of Business and Social Science, Vol. 5, No. 12; November 2014).
- Mayada Serageldin, On the Demand to Incorporate Shari'a Law into UK Law,(June 16, 2013).
From SmartCILP and elsewhere:
- F. Russell Hittinger, Natural Law and Public Discourse: The Legacies of Joseph Ratzinger, [LEXIS link] [Video of lecture], 60 Loyola Law Review 241-271 (2014).
- Peter T. Leeson, Vermin Trials, 56 Journal of Law & Economics 811-836 (2013).
- Symposium, Do the Religious Beliefs of Supreme Court Justices Influence Their Decisions?, Moment, Jan.-Feb. 2015.
- USCIRF Factsheet, Religious Freedom and Nigeria’s 2015 Elections, (Jan. 2015).
Labels:
Articles of interest
Sunday, January 18, 2015
Welcome To Law and Religion Australia
Join me in welcoming Law and Religion Australia blog to the Religion Clause sidebar. Law and Religion Australia entered the blogosphere on January 1. It is authored by Neil Foster, Associate Professor of Law at the University of Newcastle, who also describes himself as an Evangelical Christian. The new entry is particularly welcome as several blogs in area of law and religon have gone dormant in recent months. I have removed from the sidebar those that have no posts for the last 6 months. A few others are coming close to that period of dormancy. So, welcome aboard.
Labels:
Australia
Recent Prisoner Free Exercise Cases
In Jones v. Foster, 2015 U.S. Dist. LEXIS 3289 (D NV, Jan. 12, 2015), a Nevada federal district court adopted a magistrate's recommendations (2014 U.S. Dist. LEXIS 180081, Dec. 23, 2014) and denied a preliminary injunction to a Muslim inmate who complained that he was receiving the Common Fare Meal instead of a separate halal or kosher diet.
In Thierry v. Maricopa County Sheriff's Office, 2015 U.S. Dist. LEXIS 3726 (D AZ, Jan. 13, 2015), an Arizona federal district court dismissed with leave to amend a complaint by a Jehovah's Witness inmate seeking a New World Holy Scriptures Bible and complaining that there are no Jehovah's Witness bible studies or meetings, and that only six inmates per pod are permitted to attend church.
In Williams v. Cox, 2015 U.S. Dist. LEXIS 4621 (SD GA, Jan. 13, 2015), a Georgia federal magistrate judge allowed an inmate to move ahead with his claim that he was denied a requested work proscription in observance of the Feast of Shavout.
In Thierry v. Maricopa County Sheriff's Office, 2015 U.S. Dist. LEXIS 3726 (D AZ, Jan. 13, 2015), an Arizona federal district court dismissed with leave to amend a complaint by a Jehovah's Witness inmate seeking a New World Holy Scriptures Bible and complaining that there are no Jehovah's Witness bible studies or meetings, and that only six inmates per pod are permitted to attend church.
In Williams v. Cox, 2015 U.S. Dist. LEXIS 4621 (SD GA, Jan. 13, 2015), a Georgia federal magistrate judge allowed an inmate to move ahead with his claim that he was denied a requested work proscription in observance of the Feast of Shavout.
Labels:
Prisoner cases
Saturday, January 17, 2015
Illinois Bible Colleges Sue Over Rules On Granting Degrees
AP reports that a lawsuit was filed in Illinois federal district court yesterday by the Illinois Bible Colleges Association challenging Illinois Board of Higher Education rules that prevent Bible colleges from awarding full-fledged "degrees" to their graduates. They can only award "diplomas" or "certificates" since the religious schools do not offer full collegiate curriculums. The schools say that the state is violating their free exercise and speech rights, as well as ignoring the Establishment Clause, by imposing the regulations on them.
Labels:
Bible Colleges,
Illinois
Newest Charlie Hebdo Cover Generates Demonstrations-- Some Violent
Voice of America reports that the newest issue of Charlie Hebdo depicting a weeping Muhammad on the cover in response to the Paris terrorist attacks generated new demonstrations yesterday in much of Muslim Asia, Africa and the Middle East. The most violent of the demonstrations was in Niger where four people were killed and demonstrators set fire to a French cultural center and Christian churches, and attacked Christian shops. (Daily Mail reports five were killed.) Violent demonstrations also occurred in Pakistan, while peaceful demonstrations took place in many other countries. Islamic law prohibits physical representations of the Prophet Muhammad and other prophets as well. (See prior related posting.)
Meanwhile, as reported in Sunday's The Independent, British Prime Minister David Cameron has criticized remarks made made by Pope Francis at a press conference on Thursday (full text of Pope's press conference). The Pope said that people who make fun of, or make others' religion into toys, provoke and may find that "a punch awaits" them.
Meanwhile, as reported in Sunday's The Independent, British Prime Minister David Cameron has criticized remarks made made by Pope Francis at a press conference on Thursday (full text of Pope's press conference). The Pope said that people who make fun of, or make others' religion into toys, provoke and may find that "a punch awaits" them.
Labels:
Charlie Hebdo,
Muslim
Friday, January 16, 2015
Supreme Court Grants Review In 6th Circuit Same-Sex Marriage Cases
The U.S. Supreme Court today granted certiorari in four same-sex marriage cases from the Sixth Circuit: Obergefell v. James (Ohio); Tanco v. Haslam (Tennessee); DeBoer v. Snyder (Michigan); and Bourke v. Beshear (Kentucky). (Order List). In a consolidated opinion, the 6th Circuit in a 2-1 decision upheld the same-sex marriage bans in the four states. (See prior posting.) In granting review, the Supreme Court defined the questions to be argued:
The cases are consolidated and the petitions for writs of certiorari are granted limited to the following questions: 1) Does the Fourteenth Amendment require a state to license a marriage between two people of the same sex? 2) Does the Fourteenth Amendment require a state to recognize a marriage between two people of the same sex when their marriage was lawfully licensed and performed out-of-state?
Labels:
Same-sex marriage,
Supreme Court
Carson To Become First Muslim On House Intelligence Committee
According to Politico, House Minority Leader Nancy Pelosi shortly will name Indiana Rep. André Carson to the House Permanent Select Committee on Intelligence. Carson will be the first Muslim to serve on the Intelligence Committee. He currently serves on the House Armed Services Committee and worked for the Department of Homeland Security’s Fusion Center.
Suit Against India's PM Over Role In Anti-Muslim Riots Dismissed
In American Justice Center (AJC), Inc. v. Modi, (SD NY, Jan. 14, 2015), a New York federal district court dismissed on immunity grounds a suit that was brought against the current prime minister of India over his actions as Chief Minister of Gujarat during anti-Muslim rioting in 2002. The suit was brought under the Torture Victim Protection Act and the Alien Tort Statute. (See prior posting.) The court accepted the U.S. government's contention that Modi enjoys immunity from suit as a sitting head of a foreign government. The Hindu reports on the decision.
Labels:
Alien Tort Statute,
India
Michigan Must Recognize Same-Sex Mariages Entered Before Stay of District Court's Order
In Caspar v. Snyder, (ED MI, Jan 15, 2015), a Michigan federal district court issued a preliminary injunction requiring Michigan to recognize some 300 same-sex marriages of couples who married in the less 24 hours between a district court's striking down of Michigan's same-sex marriage ban and the 6th Circuit's stay of the order. In a 47-page opinion, the court held that:
once a marriage has been solemnized pursuant to a validly issued marriage license, the authorizing state cannot withdraw the status that it has awarded, even if the couples had no right to demand to be married in the first place.The court however stayed the effectiveness of its injunction for 21 days to allow an appeal to the 6th Circuit. Christian Science Monitor reports on the decision.
Labels:
Michigan,
Same-sex marriage
Canadian FLDS Leader Agrees To Court Order Barring Use of LDS Name
Last year, the Church of Jesus Christ of Latter Day Saints (the mainline Mormon Church) filed suit in Canada against Winston Blackmore, leader of a polygamous Mormon sect headquartered in Bountiful, British Columbia for misappropriation of the trademarked name, identity and reputation of the mainline Church. (See prior posting.) The National Post now reports that earlier this week Blackmore consented to a decree enjoining him from using any variation of the name "Church of Jesus Christ of Latter-day Saints" for his organization and from interfering with the mainline Church's use of the word Mormon. Under the order he is also to change the corporate name of his Canadian branch of the FLDS to "Church of Jesus Christ (Original Doctrine) Inc."
Labels:
FLDS
Suit Alleges That Drug Treatment Center Is Front For Scientology Indoctrination
MLive reports that a lawsuit was filed in a Michigan federal district court on Wednesday against Narconon Freedom Center in Albion, Michigan, alleging that the Center's drug rehabilitation program is used "to introduce Scientology and L. Ron Hubbard's 'technology' to unwitting patients." The suit, seeking $75,000 in damages, was brought by Lauren Prevec, a former patient at the Center.
Labels:
Scientology
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