JACKSON, Miss. (Legal Newsline) – A Mississippi woman can’t sue her church because it failed to discover her husband was cheating on her with other men and those extramarital activities led to her contracting HIV.
Justice James Maxwell wrote the court’s Aug. 12 decision in the case of Kim Miller, who sued the Mississippi Annual Conference of the Methodist Church (MUMC) and minister Susan Woodard.
Miller’s ex-husband, Andrew Johnson, was an MUMC minister who contracted HIV in sometime in 2012 or 2013 from one of his same-sex partners, leading to his divorce from Miller later in 2013.
Miller sued Johnson, Woodard and the church with the argument that MUMC and Woodard failed to follow church policy and procedure.
“While Miller has undoubtedly suffered a terrible wrong, the question before this Court on interlocutory appeal is whether she has established a wrong for which she can legally recover,” Justice Maxwell wrote.
“After review, it is clear that Miller seeks to hold MUMC and Woodard legally accountable for failing to follow religious doctrine and procedure. Under the First Amendment, this Court has no authority to consider and enforce religious standards.”
After Johnson confessed his affairs and HIV diagnosis to Miller, Woodard, who is a practicing psychotherapist with certifications in multiple addictions, attempted to help the couple with Johnson’s sex addiction.
The day after Johnson’s revelation, MUMC placed him on leave. Its book of discipline stipulates that practicing homosexuals can’t serve in ordained ministry.
Woodard had suggested Johnson delete pornographic material from his computer to help cope with his sex addiction. Johnson sued Woodard because of this, claiming she interfered with a civil action and had negligently or intentionally concealed information.
Those claims were thrown out by a Hinds County judge, who later refused to throw out the remaining claims at the summary judgment phase. The Supreme Court’s ruling overturns that decision.
“Constitutionally, this Court cannot impose higher legal duties on MUMC and Woodard on the basis of their respective religious roles as a church conference and a minister within that conference,” Maxwell wrote.
Johnson, meanwhile, had his summary judgment arguments rejected by both courts. He had argued the claims against him were barred by their divorce agreement, but he had waited years into litigation to raise that defense.
“Johnson then waited for more than two-and-a-half years to pursue his claim that Miller expressly released her claim against him in their divorce settlement,” Maxwell wrote. “And even then, he merely joined MUMC’s motion for summary judgment, in which MUMC asserted Miller had released her claims against Johnson in their divorce settlement, absolving MUMC from any vicarious liability.”