A federal judge in Seattle rejected a libel lawsuit by the Satanic Temple, concluding that the claim was barred by the Establishment Clause.
Here is a portion of a decision by U.S. District Judge Richard Jones in United Federation of Churches, LLC d/b/a The Satanic Temple v. Johnson, reaffirmed on April 12 in the court’s denial of a motion for reconsideration:
[According to the Complaint,] Plaintiff United Federation of Churches, LLC (“The Satanic Temple”) is a religious organization. As such, its mission is to “encourage benevolence and empathy among all people, reject tyrannical authority, advocate practical common sense and justice, and be directed by the human conscience to undertake noble pursuits guided by the individual will.” To that end, it espouses “seven fundamental tenets.” Among them are beliefs such as, “[o]ne’s body is inviolable, subject to one’s own will alone,” and “[o]ne should take care never to distort scientific facts to fit one’s beliefs.”
Two ex-members of the Satanic Temple implied “that the Washington Chapter [of the Temple] had supported ‘ableism, misogyny, and racism,’ transphobia, and police brutality” and made supposedly “false claims that” the Satanic Temple “leadership is cozy with the alt-right, are white supremacists,” and “are generally insufficiently leftist.” The Temple sued for defamation, but the judge dismissed the claim:
The First Amendment limits the role of civil courts in resolving “religious controversies that incidentally affect civil rights.” Known in this circuit as the “doctrine of ecclesiastical abstention,” the doctrine maintains that “civil courts may not [ ]determine the correctness of an interpretation of canonical text or some decision relating to government of the religious polity.” …
This claim asserts that certain Defendants made false public statements about The Satanic Temple, a religious organization…. [But t]he Court may not resolve the defamation claim without delving into doctrinal matters. To determine whether Defendants’ statements were defamatory, the Court or jury must inevitably determine that the statements were false. That would require the Court or jury to define the beliefs held by The Satanic Temple and to determine that ableism, misogyny, racism, fascism, and transphobia fall outside those beliefs. That the Court cannot do without violating the First Amendment….
Professor Eugene Volokh says the Court’s reliance on the Establishment Clause was dubious, because “the claims weren’t about the true meaning of religious doctrine, but rather about the alleged actions of the group’s leaders—it seems to me that such claims could be decided without considering doctrine (though perhaps they wouldn’t be libelous for other reasons, such as that they are opinions).”
