Williams v. Kingdom Hall
Williams v. Kingdom Hall, 2021 UT 18 (Durrant, C.J.)
Four Elders in the Jehovah’s Witness church conducted a disciplinary hearing to determine if a 14-year-old girl in their congregation—who was sexually assaulted by another congregant—was penitent. During the hearing, they played audio of her being raped for four to five hours, despite her distress and petitions for them to stop. She sued the church for intentional or negligent infliction of emotional distress. The district court dismissed her claims under outdated Establishment Clause caselaw. The Utah Court of Appeals affirmed. The Utah Supreme Court reversed, holding:
- The district court and court of appeals erred in applying and affirming a holding based on the Lemon test, which the United States Supreme Court disavowed in recent years. On remand, the district court should look to the advice in American Legion, focusing on “the particular issue at hand,” “looking to history for guidance,” and identifying “an overarching set of principles” that should be applied in each case.