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In Washington v. African Methodist Episcopal Church, Inc., Case No. 11-CV-6087-CJS, 2011 WL 4352404 (W.D.N.Y. Sept. 16, 2011), the court ruled that the Free Exercise Clause of the First Amendment precluded subject matter jurisdiction over a pastor’s and his wife’s claim against their former church and bishop based on breach of contract, intentional infliction of emotional distress, prima facie tort, and loss of consortium
In General Conf. Corp. of Seventh-day Adventists v. McGill, No. 1:06-cv-01207 and 1:11-mc-00003, 2012 WL 1155465 (W.D. Tenn. Ap. 5, 2012), the court held that the Religious Freedom Restoration Act (“RFRA”) may not be used as a claim or defense in lawsuits between private parties
In St. John’s Church in the Wilderness v. Scott, No. 11CA0508, 2012 WL 1435945 (Colo.App. Ap. 26, 2012), the appellate court held that the trial court did not abuse its discretion in prohibiting protesters from entering the church’s property, and by enjoining the use of large posters depicting mutilated fetuses in a manner reasonably likely to be viewed by children
