Satanic Temple Lose Libel Lawsuit

A 2021 Judge Richard Jones decision (W.D. Wash. United Federation of Churches, LLC, d/b/a The Satanic Temple, v. JohnsonYesterday, the denial or reconsideration motion was denied.

[According to the Complaint,]Plaintiff United Federation of Churches, LLC “The Satanic Temple” is a religious organisation. The organization’s purpose is to promote benevolence among all people, reject tyrannical power, encourage practical common sense and justice and allow the human conscience to direct them to noble pursuits that are guided by their individual will. The organization adheres to seven fundamental principles. These beliefs include the belief that “[o]”Nes’s body remains inviolable. One’s will is all that matters.”[o]You should not try to alter scientific facts in order to support your beliefs.

Two former members posted material “suggest[ing]Washington Chapter [of the Temple]Had supported “ableism and misogyny and racism”, as well as police brutality and transphobia” and levied allegedly false claims. [The Satanic Temple]Leadership is friendly with the alt-right. Are white supremacists? [and]They tend to be insufficiently leftist. Temple sued for libel. However, the court denied the claim.

According to the First Amendment, civil courts are not allowed to resolve “religious conflicts that may affect civil rights.” This doctrine is known in the circuit as “doctrine ecclesiastical abstention” and it holds that civil courts cannot resolve “religious controversies that incidentally affect civil rights.” [ ]Determine whether a canonical text interpretation is correct or if a decision regarding government of the religion polity has been made correctly. …

This claim asserts that certain Defendants made false public statements about The Satanic Temple, a religious organization…. [But t]The Court cannot resolve the defamation case without addressing doctrinal issues. The Court must invariably determine that the defendants’ statements are false to determine whether they were defamatory. To do this, the Court/jury would have to identify the beliefs of The Satanic Temple, as well to decide that misogyny and racism are not included within those beliefs. That the Court cannot do without violating the First Amendment….

Banner 3

I’m not sure that this is right, given that 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). Even so, I want to inform our readers about the outcome.

There were other claims, however, under the Computer Fraud and Abuse Act and Anti-Cybersquatting Consumer Protection Act. Washington Consumer Protection Act and the state tort of interference in business expectancy were all dismissed.