In weighing a defamation case against an Iowa church, the state’s Supreme Court has upheld a decision limiting court involvement in religious matters.
The case was initiated in 2017 by Ryan Koster, a former member of Harvest Bible Chapel, a nondenominational Christian church in Davenport. In 2005, Koster began attending the church, where he later met his future wife, Lisa. The couple married in 2007 and had two children.
The Kosters regularly participated in a church activity known as Small Group, in which individuals discussed their lives and weekly scripture readings. The Kosters’ group was attended by 10 couples, including defendant Garth Glenn, a Harvest pastor, and his wife.
Harvest practices what it describes as Biblical Soul Care, “speaking the truth, in love, in your circle of influence.” Essentially, the members provided counseling to one another. Although there was no formal confidentiality agreement, there was discussion that the groups were “a safe place to share,” that that what was said in the group sessions would remain there.
The Kosters, the Glenns and a third couple became close friends and later formed a new counseling group consisting of just the six individuals.
In 2015, Lisa Koster called Pastor Glenn and reported a young female relative had said Ryan had touched her under her underwear. She immediately obtained a protective order, then sent emails to Harvest staff members about sexual abuse allegedly committed by her husband.
Pastor Glenn then sent an email to his fellow pastors and directors at Harvest. It referenced unspecified events involving the couple that had resulted “in police and DHS involvement.” Glenn added that “Lisa and the kids are safe but things are just now coming to a head.”
Pastor Glenn’s email went on to predict that Ryan Koster “will attempt to reach out to whoever will give him an ear or be an ally” and to “ask that you do not allow him to serve in any capacity no matter how minimal it may be.”
The next day a “Security Alert” flyer with Ryan’s photograph was posted in an area of the church accessible to Harvest staff. It bore a picture of Ryan and stated that the “court finds that the protected party (Lisa Koster) and the children … are in danger of physical harm from Ryan Koster (husband and father).”
On May 3, Pastor Glenn sent a lengthier email to members of the 10-couple Small Group stating that he hesitated to share any specifics regarding the Kosters, but he referenced the protective order and said, “I trust you can connect the dots and realize that what we are talking about are horrific allegations … Ryan is denying the allegations and believes (the child) is outright lying.”
After an investigation, DHS concluded the allegations were not founded. Lisa later filed two additional reports of child sexual abuse. DHS did not substantiate either of those reports. Law enforcement also declined to pursue criminal charges against Ryan.
In addition, when the Koster’s divorce was finalized, the court awarded Ryan physical custody of the children, with the finding that Lisa lacked credibility.
In 2017, Ryan filed a lawsuit in the Scott County District Court against Harvest and Pastor Glenn, alleging breach of confidentiality; invasion of privacy involving “false light” publicity; and defamation.
The district court later ruled Ryan’s invasion of privacy claim could not stand because the emails had been disseminated only to church staff and group members and so the required “publicity” element of the statute had not been met.
The court also noted that there was no evidence to suggest Glenn “knew that the allegations were false or recklessly disregarded the truth.”
As to the breach of confidentiality claim, the church noted there was no specific agreement between Glenn and Ryan and so, to decide this claim would require the court to examine Harvest’s tenets and practices, a process that would run afoul of the First Amendment.
In its ruling upholding the district court’s decision, the Iowa Supreme Court said that “because determining whether Pastor Glenn, and derivatively Harvest Bible Chapel, breached a fiduciary duty of confidentiality to Ryan arising out of group discipleship discussions would require our courts to interpret HBC doctrine and practices, such a claim cannot proceed in our courts … Pastor Glenn’s emails, whatever their flaws, were sent by a religious leader exclusively to staff and members of that religious community.”