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Allard v. Church of Scientology

Citations: 58 Cal. App. 3d 439; 129 Cal. Rptr. 797; 1976 Cal. App. LEXIS 1529Docket: Civ. 45562

Court: California Court of Appeal; May 18, 1976; California; State Appellate Court

Narrative Opinion Summary

In this case, the plaintiff sued the defendant, the Church of Scientology, for malicious prosecution, while the Church filed a cross-complaint for conversion. The jury awarded the plaintiff $50,000 in compensatory damages and $250,000 in punitive damages, with a judgment favoring the plaintiff on the cross-complaint. The Church appealed on grounds including alleged trial misconduct, insufficient evidence for malicious prosecution, and excessive damages. The court found no prejudicial misconduct by the plaintiff’s counsel and upheld the jury's findings, including the denial of judgment notwithstanding the verdict, as there was evidence of malicious prosecution. The trial court's instructions on damages were deemed appropriate, allowing presumed damages for reputation and emotional distress without proof. Although the court reduced punitive damages to $50,000, it affirmed the compensatory damages, rejecting the Church's argument of prejudice. The voir dire process was found adequate, dismissing claims of juror bias. The case highlighted the relevance of Church policies in establishing malicious prosecution. The court's decision modified the judgment to reflect reduced punitive damages, awarding costs on appeal to the plaintiff while affirming the overall judgment.

Legal Issues Addressed

Compensatory and Punitive Damages

Application: The jury awarded the respondent $50,000 in compensatory damages and $250,000 in punitive damages, but the court found the punitive damages excessive and reduced them to $50,000.

Reasoning: The punitive damages in the case were initially awarded at $250,000, but the court found this amount excessive compared to the compensatory damages of $50,000, indicating that animosity influenced the punitive award. Consequently, the court reduced the punitive damages to $50,000.

Fair Trial and Religious Freedom

Application: The appellant's claims of misconduct by respondent's counsel affecting the right to a fair trial and infringing on religious freedom were dismissed by the court.

Reasoning: In response, the court found no prejudicial misconduct by respondent's counsel, determining that the trial was conducted fairly despite minor inappropriate statements.

Jury Instructions on Damages

Application: The court provided a modified instruction on damages, emphasizing that they must be awarded for presumed losses, including damage to reputation and emotional distress, without needing proof.

Reasoning: A modified version of BAJI Nos. 14.00 and 14.13 was provided, instructing that if the jury finds the plaintiff entitled to a verdict against the defendant, damages must be awarded to reasonably compensate for presumed losses including damage to reputation, humiliation, and emotional distress, without the need for proof of such harm.

Jury Voir Dire on Religious Biases

Application: The court found the voir dire process adequate in addressing potential juror biases regarding the parties and their knowledge of Scientology.

Reasoning: Furthermore, the trial court's voir dire process was adequate, as jurors were questioned about potential biases regarding the parties and their knowledge of Scientology.

Malicious Prosecution Claims

Application: The jury found sufficient evidence to support the respondent's claim of malicious prosecution, and the trial court denied the motion for judgment notwithstanding the verdict.

Reasoning: The trial court also correctly denied the motion for judgment notwithstanding the verdict, as evidence suggested that the church's agent acted within his employment scope when committing theft, supporting the claim of malicious prosecution.

Relevance of Church Policy in Malicious Prosecution

Application: The court deemed church policy statements relevant to the case as they illustrated a policy permitting deception or harm, impacting the credibility of witnesses.

Reasoning: The introduction of the church's policy statements was pertinent to the credibility of the witnesses. They illustrated a policy permitting Scientologists to deceive or harm perceived enemies, thus linking to the case's issues.