John Doe 122 v. Marianist Province of the United States and Chaminade College Preparatory, Inc., and Fr. Martin Solma

Summary

The court affirmed summary judgment on Doe's negligence-based claims because controlling precedent bars claims requiring judicial evaluation of a religious institution's supervision of clergy under the Free Exercise Clause. It vacated summary judgment on the intentional-failure-to-supervise claim because personnel records and expert testimony could support a jury finding that Chaminade knew of a substantial risk of abuse and disregarded it. The case was remanded for further proceedings, including consideration of the statute-of-limitations defenses.