F.G., Plaintiff-Respondent v. Reverend Alex MacDonell

Summary

The Supreme Court of New Jersey held that a parishioner may sue a clergyman for breach of fiduciary duty arising from sexual misconduct during pastoral counseling, and affirmed that such claims do not violate the First Amendment. It allowed the breach‑of‑fiduciary‑duty claim against Reverend MacDonell and, subject to a hearing on religious entanglement, against Reverend Harper, and also permitted a negligent‑infliction‑of‑emotional‑distress claim against MacDonell.