Conti

In this case we consider the duty owed by a religious organization to one of its members who has been harmed by another member. Candace Conti, formerly a member of the North Fremont Congregation of Jehovah’s Witnesses (Fremont Congregation or Congregation), sued the Congregation and Watchtower Bible and Tract Society of New York, Inc. (Watchtower), the Jehovah’s Witnesses’s headquarters at the time, for damages for her sexual abuse as a child by Jonathan Kendrick (Kendrick), another member of the Congregation. Before Conti was molested, the Congregation and Watchtower (hereafter collectively defendants) elders and officials learned that Kendrick had molested another child. Conti sought to hold defendants liable for failing to warn the Congregation or her parents that Kendrick was a child molester, and for failing to limit and supervise his participation in church activities. A jury found defendants liable for compensatory damages to Conti, and held Watchtower liable for punitive damages.

We hold that defendants had no duty to warn the Congregation or Conti’s parents that Kendrick had molested a child, but that defendants can be held liable for failing to limit and…