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

Summary

The New Jersey Supreme Court held that a parishioner may maintain a breach of fiduciary duty claim against a clergyman for sexual misconduct that occurred during pastoral counseling, and may also maintain a similar claim against a second clergyman who disclosed the relationship, provided the court can resolve the claim by neutral principles without entangling itself in church doctrine. The Court affirmed that the First Amendment does not shield clergy from such liability.