O'Neil v. Schuckardt

Jerry O’Neil (Jerry) (plaintiff), a non-Catholic, married and had five children with Pauline O’Neil (Pauline), who was not only a devout Catholic but also a member of the fundamentalist Fatima Crusade (defendant) sect. The Fatima Crusade did not observe modern reforms to Catholicism and considered marriages between Catholics and non-Catholics to be invalid. Pauline’s mother, Alvina Urban (defendant), convinced Pauline and her children to live in a boarding house run by the sect. Jerry alleged that members of the religious community prevented him from seeing Pauline when he attempted to visit, attempted to convince Pauline that the marriage was invalid, mistreated the children, and told the children that Jerry was not a true father to them. Jerry and Pauline were divorced. The divorce decree included an order restraining Pauline from imposing religious beliefs on her children. Evidence showed that at least one member of the sect, Pauline’s sister (defendant), was aware of this decree, but the religious indoctrination of the children continued. Jerry brought suit against Francis Schuckardt (defendant), bishop of the Fatima Crusade; the Fatima Crusade itself; Urban; Pauline’s sister; and other members of the sect for alienation of Pauline’s affections and invasion of Jerry’s, Pauline’s, and the children’s privacy. The jury awarded a verdict for Jerry, but the trial court granted the defendants’ motions for judgment notwithstanding the verdict. Jerry appealed. The Idaho Supreme Court granted certiorari.