Varner v. Stovall
United States Court of Appeals for the Sixth Circuit
500 F.3d 491 (2007)
- Written by Angela Patrick, JD
Facts
Janniss Varner (defendant) hired someone to shoot her abusive boyfriend. The boyfriend was injured, but he did not die until he was shot again over two years later. While the police were investigating the boyfriend’s murder, they found private journals in which Varner had written notes and prayers to God about her boyfriend’s abuse and about how she had hired someone to shoot him two years earlier. Varner was charged with assault and attempted murder. At trial, the court allowed the journals to be admitted as evidence. Varner was convicted and appealed. On appeal, Varner argued that the clergy-communicant privilege violated the First Amendment to the United States Constitution because it covered only religious communications made to clergy members and discriminated against people who believed in talking to God directly. Varner claimed that the privilege should be extended to religions that speak directly to God. Varner believed that this extension would make the privilege apply to her journal entries and would mean that the journals should have been excluded from her trial.
Rule of Law
Issue
Holding and Reasoning (Sutton, J.)
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