# In re Gothard Supreme Court of Texas, No. 24-0236 **In re Gothard, No. 24-0236, is before the Supreme Court of Texas. Key issue: The Court denied mandamus in a suit by two women who were sexually abused by family members against Bill Gothard and the Institute in Basic Life Principles, which challenged the civil-conspiracy claim under Rule 91a and the ecclesiastical-abstention doctrine, and Chief Justice Blacklock, joined by Justices Devine and Sullivan, dissented from the denial.** Practice areas: civil procedure, federal constitution, texas constitution ## Key issues - The Court denied mandamus in a suit by two women who were sexually abused by family members against Bill Gothard and the Institute in Basic Life Principles, which challenged the civil-conspiracy claim under Rule 91a and the ecclesiastical-abstention doctrine, and Chief Justice Blacklock, joined by Justices Devine and Sullivan, dissented from the denial. - The dissent would have granted the petition and required repleading because the petition's main link between Gothard and the abuse is the content of his religious teachings on authority, sexuality and family, which the dissenters said cannot be tried in a Texas court. ## Factual History 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" (Brief on the Merits (Relators), PDF pp. 22-23; Blacklock, C.J., dissenting, PDF p. 2). ## Procedural History 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. ## Issues Presented 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 (Brief on the Merits (Relators), PDF pp. 6-7). ## Legal Arguments **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 (Brief on the Merits (Relators), PDF p. 24; Brief on the Merits (Real Parties in Interest), PDF pp. 10, 24). ## Stated Reasons the Court Should Take the Case Not applicable—the petition was denied. ## Practice Area Tags civil-procedure, federal-constitution, texas-constitution ## Procedural Posture/Vehicle 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). ## Amicus Involvement None noted ## Court's 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 (Blacklock, C.J., dissenting, PDF pp. 2-6). ## 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 (Blacklock, C.J., dissenting, PDF pp. 1-6). --- Source: The SCOTX Report, https://scotxreport.com/cases/24-0236. AI-generated summary of the Court's opinion, orders and the parties' briefs, with pin cites to the page of each document; verify against the Court's own documents at search.txcourts.gov.