Woodard v. Miller
Annotate this CaseIn the aftermath of her divorce from ex-Methodist minister Andrew Johnson, Kim Miller sued not only Johnson but also his employer, the Mississippi Annual Conference of the United Methodist Church (MUMC). Miller also sued fellow MUMC minister Susan Woodard. Her claims against Johnson were aimed at his risky extramarital sexual behavior, which led to Johnson contracting HIV and later infecting Miller with the virus. Miller based her claims against MUMC and Woodard on her allegation that, had the conference and the fellow minister followed United Methodist policy and procedure, they would have discovered Johnson’s behavior and remedied it or warned Miller before she contracted HIV. The question before the Mississippi Supreme Court on interlocutory appeal was whether she established a wrong for which she could legally recover. After review, the Court found "it is clear that Miller seeks to hold MUMC and Woodard legally accountable for failing to follow religious doctrine and procedure. Under the First Amendment, this Court has no authority to consider and enforce religious standards. Thus, MUMC and Woodard are entitled to summary judgment." The Court found Miller’s claims against her ex-husband, Johnson, were not barred by the First Amendment. Still, Johnson insisted he was entitled to summary judgment based on a mutual release in Miller and Johnson’s divorce settlement. The Court found Johnson did not pursue his affirmative defense based on the release for more than two and a half years. By that time, the trial court deemed this defense waived. And after review, the Court held the trial court did not abuse its discretion by denying Johnson summary judgment on this basis. The trial court's orders denying MUMC’s and Woodard’s motions for summary judgment were reversed; the order denying Johnson’s motion for summary judgment was affirmed and Miller’s claims against Johnson remanded to the trial court for further proceedings.
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