F.G. v. MacDonell
New Jersey Supreme Court
696 A.2d 697 (1997)
Rector Alex MacDonell (defendant) induced F.G. (plaintiff), a parishioner he was counseling, into an extramarital sexual relationship. F.G. later confided in assistant rector Harper (defendant), who allegedly persuaded her to let him disclose her name to the congregation, then did so in letters and sermons that mischaracterized what had happened. F.G. sued both men for negligent counseling, emotional distress, and breach of fiduciary duty. The trial court dismissed the malpractice and fiduciary-duty claims, the appellate court reversed, and MacDonell and Harper appealed to the New Jersey Supreme Court.
Whether courts may recognize a breach-of-fiduciary-duty claim arising out of the pastor-parishioner counseling relationship, as distinct from a clergy-malpractice claim.