Molko v. Holy Spirit Association for the Unification of World Christianity

In 1978, David Molko (plaintiff) was recruited to attend a social gathering and persuaded to remain with the group and participate in the group’s prescribed activities. These tightly planned activities included full days of strenuous exercises, lectures, and group discussions. Molko repeatedly inquired if the group was affiliated with a religious organization and was told that it was not. Molko expressed his desire to leave but was persuaded to remain. Eventually, Molko was told that the group was part of the Unification Church (the church) (defendant). Despite this revelation, Molko decided to stay with the group, and he donated money to the church when asked to. After becoming a member of the church, Molko was abducted by individuals hired by his parents, who persuaded him to leave the church. Molko alleged that the church had brainwashed him and sued for fraud, seeking restitution of the money he had given the church because it had been obtained from him by undue influence. The church conceded that church members had misrepresented the church’s identity to induce Molko to participate in church activities but argued that because Molko knew the church’s identity prior to becoming a member, Molko did not rely on the misrepresentation in deciding to join the church. The trial court granted summary judgement for the church, and the appeals court upheld the ruling. Molko appealed.