In Hullibarger v. Archdiocese of Detroit, (MI App., July 8, 2021), a Michigan state appellate court held that the ecclesiastical abstention doctrine requires dismissal of a suit claiming that a priest's sermon at the funeral of plaintiff's son amounted to intentional infliction of emotional distress, misrepresentation and invasion of privacy. The court also held that the ecclesiastical abstention doctrine requires dismissal of a negligent hiring, supervision and retention claim. According to the court:
Plaintiff’s son committed suicide in early December 2018, but his family kept the manner of his death from the public. Plaintiff’s pastor, defendant Father Don LaCuesta, officiated at the funeral and during his homily revealed the suicide of plaintiff’s son to the public. He then proceeded to preach about suicide as a grave sin and specifically about how it endangered the immortal soul of plaintiff’s son.
