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Paul v. Watchtower Bible and Tract Society of New York, Inc.

United States Court of Appeals for the Ninth Circuit

819 F.2d 875 (1987)

Facts

Janice Paul (plaintiff) was raised in the Jehovah’s Witness Church (the church) (defendant). When Paul was about 24 years old, she wrote a letter to the church elders and withdrew from the church. At the time Paul withdrew, there was no express sanction for withdrawing. Paul maintained friendships with her friends in the church. Later on, the church, acting through Watchtower Bible and Tract Society, issued a new interpretation of its rules and determined that because Paul had left the church, Paul must be shunned. Church members could not speak to her, nor even acknowledge her. Paul sued the church for defamation, invasion of privacy, fraud, and outrageous conduct. The trial court granted the church’s motion for summary judgment. Paul appealed.

Rule of Law

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Holding and Reasoning (Reinhardt, J.)

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