Turner v. Unification Church

Majority - Pettine, Chief Judge

No, the plaintiff's complaint fails to state any claims upon which relief may be granted, although the defendants are not immunized by the First Amendment for the alleged conduct. The court first found that the First Amendment's free exercise clause does not prohibit the court from entertaining the suit, as it protects religious belief absolutely, but allows regulation of religious 'operational activities' that endanger public safety, threaten disorder, endanger health, or drastically differ from societal norms. Allegations of involuntary servitude, which seriously affect a follower and violate fundamental tenets of American society, fall outside First Amendment protection. Regarding claims under 42 U.S.C. §§ 1981, 1983, and 1985: Section 1981 was dismissed because it applies only to racial discrimination, and Turner did not allege race as a motivating factor. Section 1983 was dismissed due to the absence of state action. Section 1985(3) requires a 'racial, or perhaps otherwise class-based, invidiously discriminatory animus,' and while the court acknowledged arguments for expanding it to religious bias, it found that Turner failed to allege that the defendants' conspiracy was motivated by any such class-based discriminatory animus. For an implied cause of action directly under the Thirteenth Amendment, the court declined to expand the rationale of Bivens v. Six Unknown Named Agents, noting that Bivens cases involve federal agents, whereas this case involved alleged private wrongdoing that could be adequately redressed by traditional state tort law remedies. Implying a Thirteenth Amendment cause of action for private conduct would unnecessarily 'constitutionalize' a large portion of state tort law, especially since Congress has already provided statutory protections for Thirteenth Amendment rights (e.g., §§ 1981, 1985). Regarding implied civil causes of action from federal criminal statutes (18 U.S.C. §§ 1581, 1583, and tax provisions 26 U.S.C. §§ 6674, 7204, 7202): Applying the Cort v. Ash factors, the court found no basis to imply such remedies. For 18 U.S.C. § 1581 (peonage), Turner failed to allege indebtedness, a required element. For 18 U.S.C. § 1583 (involuntary servitude), it was unclear if psychological control alone constituted involuntary servitude, and there was no legislative intent to create a civil remedy; existing state and federal civil rights laws provided sufficient remedies. For the tax statutes, the court found no explicit or implicit intent for civil remedies and noted the existence of administrative remedies and criminal-only language. Under the Fair Labor Standards Act (FLSA), Turner was not an 'employee' as defined by 29 U.S.C. § 203 because she did not contemplate monetary or tangible compensation, but rather expected her work to 'create a better world.' This spiritual consideration does not establish an employer-employee relationship under the FLSA. Finally, for Rhode Island common law claims: A tort claim for alienation of affection of parents and friends was rejected as Rhode Island law only recognizes this for spouses, and Turner was an adult at the time. A quantum meruit claim failed because Turner never alleged a reasonable expectation of monetary or tangible payment for her services, but rather a desire to 'create a better world,' which is insufficient to imply a contract under state law, especially for services rendered out of charitable, religious, or humane motives.