Phoebe Merritt and Abigail Doty sued their abusers, Stanley and Samuel Grant, and also Bill Gothard, his ministry the Institute in Basic Life Principles (IBLP) and its A.L.E.R.T. program for civil conspiracy to commit and conceal sexual abuse. The only overt acts alleged are the Grants', and the petition contains no allegation that Gothard or IBLP knew of or communicated with the family; the alleged link is that Gothard's teachings on patriarchal authority and children's duty of loyalty created "ideal victims".¹

Gothard and IBLP moved to dismiss the conspiracy claim under Rule 91a on the ground that it was barred by the First Amendment and the ecclesiastical-abstention doctrine and had no basis in fact or law; the trial court denied the motions on October 27, 2023, and the Twelfth Court of Appeals denied mandamus on February 22, 2024. The Court requested merits briefing and denied mandamus on June 27, 2025, dismissing the motion for temporary relief as moot, and later denied rehearing on December 19, 2025.

Original petition for writ of mandamus after the court of appeals denied relief; denied June 27, 2025, with Justice Young not participating and rehearing denied December 19, 2025 (Docket).

Whether the trial court abused its discretion in denying the Rule 91a motions because the conspiracy claim inextricably depends on the substance and interpretation of IBLP's religious teachings.¹

Gothard and IBLP (Relators): the claim is rooted in constitutionally protected teaching and publication and would require a court and jury to judge what is biblical, so the First Amendment and ecclesiastical abstention bar it and it has no basis in law.

Merritt and Doty (Real Parties in Interest): the case is about a leader abusing his power and an organization that facilitated abuse, not religion, and the petition pleads specific facts of a conspiracy sufficient to give fair notice.¹

Not applicable⁠—the petition was denied.

None noted

Reasoning

The dissent reasoned that courts may not risk entanglement with matters inextricably intertwined with doctrine and that the petition's primary allegation is that Gothard's teachings on sex and family were intended to create victims, which would require a judge or jury to evaluate the correctness of his reading of the Bible and would implicate a material percentage of American religious leaders. The plaintiffs may seek justice against the perpetrators, but the ministry claims should be repleaded without asking a court to judge religious teachings; the dissent also doubted the petition states a cognizable conspiracy claim without allegations of specific intent to harm these plaintiffs.¹

Disposition

Petition for writ of mandamus denied and motion for temporary relief dismissed as moot; Justice Young did not participate (Docket).

Vote Breakdown

Chief Justice Blacklock, joined by Justices Devine and Sullivan, dissented from the denial of mandamus.²