Pleasant Glade Assembly of God v. Schubert

Tom and Judy Schubert and their teenage daughter Laura (plaintiffs) were members of the Pleasant Glade Assembly of God church (the church) (defendant). One evening, Laura attended a youth-group event in which she and other church members, under the youth minister’s (defendant) supervision, stayed up very late to cast out demons from the church. During a church service the next day, Laura collapsed, either from a religious/spiritual experience or from fatigue, and other church members (defendants) laid hands on Laura by forcibly holding her down while she kicked and screamed. Laying hands was the church’s customary practice in which church members placed their hands on another member and prayed to rid the member of demons. During a subsequent service, Laura again collapsed and church members again laid hands on Laura, resulting in Laura suffering scrapes and bruises. Tom later told the church’s senior pastor (defendant) that Laura was having nightmares. Psychologists attributed the nightmares (and other symptoms like sleeplessness, hallucinations, etc.) to traumatic stress disorder associated with the previous discussions of demons and Laura’s physical restraint. The Schuberts sued for torts, including negligence, intentional infliction of emotional distress, false imprisonment, and assault. The Schuberts alleged that Laura suffered physical distress and psychological/emotional injuries. The church moved for a protective order and dismissal, claiming the lawsuit was an unconstitutional burden on the church’s practices in violation of the Free Exercise Clause. The trial court denied the motion. The court of appeals granted the church’s motions in a subsequent mandamus proceeding and held that the negligence and intentional-infliction-of-emotional-distress claims were religious claims that would require a trier of fact to assess the validity of the church’s beliefs and therefore that those claims were barred by the Free Exercise Clause. Thereafter, a jury found in the Schuberts’ favor on the false imprisonment and assault claims and awarded Laura damages, in part for pain and suffering. The church appealed, and the court of appeals affirmed. The church appealed to the Texas Supreme Court.