Missouri Court of Appeals, Southern District / Jan 17, 2025
JANE DOE, a minor by next friend, T.N., Appellant vs. FIRST BAPTIST CHURCH OF PIERCE CITY, MISSOURI, Respondent
Jane Doe, a minor, sued First Baptist Church of Pierce City (FBC) for negligence, alleging sexual assaults suffered while participating in FBC's youth ministries program. The circuit court granted summary judgment for FBC, concluding that the First Amendment barred the negligence claim. The appellate court affirmed, holding that the First Amendment prohibits courts from entertaining negligence claims against religious organizations that would require excessive entanglement in religious doctrine, policy, and administration. The court also found that FBC was not required to plead the First Amendment as an affirmative defense, as it negates an element of the plaintiff's prima facie case.