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Richelle L. v. Roman Catholic Archbishop of San Francisco

2003 Cal. App. LEXIS 225 (2003)

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Richelle L. v. Roman Catholic Archbishop of San Francisco

California Court of Appeal
2003 Cal. App. LEXIS 225 (2003)

Facts

Richelle L. (plaintiff) was a parishioner at a Roman Catholic church where Reverend FN (priest) (defendant) was a priest. Richelle was a deeply religious woman who had remained chaste until the priest initiated a sexual relationship with her. The priest, who claimed that he had also remained chaste, convinced Richelle to have sex with him in the church rectory, assuring her that doing so would not be improper. The priest called Richelle daily, leaving romantic messages on her answering machine, and told Richelle that he planned to stay in the area after he retired so that he could be near her. In reality, the priest had seduced a number of parishioners at several churches. Richelle sued the priest, alleging breach of fiduciary duty, fraud and deceit, and intentional and negligent infliction of emotional distress. The priest filed a demurrer, arguing that Richelle’s lawsuit was barred by the First Amendment to the United States Constitution because the suit would force the court to evaluate the way the priest had carried out his ecclesiastical duties, excessively entangling the court in the religious beliefs and practices of the church. The trial court sustained the demurrer, and Richelle appealed.

Rule of Law

Issue

Holding and Reasoning (Kline, J.)

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