Conti v. Watchtower Bible &Tract Soc'y of N.Y.
Annotate this CaseConti and Kendrick were members of the Fremont Congregation of Jehovah’s Witnesses in the 1990s, and Kendrick was a ministerial servant, performing administrative tasks for the congregation. Conti alleged that Kendrick began molesting her when she was nine years old in 1994. Before Kendrick molested Conti, the Congregation elders learned that he had molested his stepdaughter. Kendrick’s wife also reported the incident to the police. Kendrick admitted touching his stepdaughter’s breast, and was convicted of a misdemeanor. Congregation Elders did not learn of the police report until a couple of years later. Ultimately, Conti sued for failure to warn that Kendrick was a child molester, and for failure to limit and supervise Kendrick’s participation in church activities. A jury awarded compensatory and punitive damages. The court of appeal reversed in part, holding that the defendants had no duty to warn the Congregation or Conti’s parents that Kendrick had molested a child, but can be held liable for failing to limit and supervise Kendrick’s “field service,” a church-sponsored activity where members go door-to-door preaching in the community. Kendrick had unsupervised access to Conti during field service that he used as opportunities to molest her.
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