Cultic Studies Journal, Vol. 8, No. 1, 1991, Page 52
39. Molko, 46 Cal. 3d at 1117.
40. Id. at 1118.
41. Id.
42. Id. at 1125. As to the church‟s cross-claim against the deprogrammers, the supreme
court found there was a triable issue of fact as to whether the deprogrammer was part
of an ongoing conspiracy to prevent church members from freely exercising their
religious beliefs through interstate travel, and thus subject to an injunction to prevent
future forcible deprogramming activities. Id. at 1127-8.
43. 213 Cal. App. 3d 729 (1989), cert. denied _U.S. _,110 S. Ct. 2168, 109 L. Ed. 3d 498
(1990).
44. See Denniston, Supra n. 21.
45. George, 213 Cal. App. 3d at 757.
46. Pen. Code &236.
47. Pen. Code &237.
48. George, 213 Cal. App. 3d at 766.
49. Cult apologists argue the entire brainwashing theory must be predicated by force or
threat of force. Telephone interview with Ford Greene, August 1, 1990.
50. George, 213 Cal. App. 3d at 729
51. Robin‟s libel claim was not supported by the appellate court, because the statements in
the “official position” circulated by the Krishnas that were not true were merely opinion.
The court did find evidence to support the jury‟s finding that the document was
defamatory as to the mother, since the document alleged physical abuse of her daughter
as a reason for her leaving home, a statement of fact determined to be false. Robin‟s
wrongful death claim also succeeded, as Marcia had warned the Krishna leadership of
her husband‟s heart condition but the Krishnas had disregarded the foreseeable harm
and persisted in hiding Robin from the family.
52.Wollersheim v. Church of Scientology, 212 Cal. App. 3d 872, 879 (1989), cert. denied,
110 S.Ct. 1937, 109 L.Ed. 2d 300 (1990).
53. These sessions are designed to train an individual to have no emotional response
whatever to verbal stimuli. For a detailed description of this process and its effects, see
F. Conway &J. Siegelman, Snappping, supran. 14, at 161-68.
54. See Allard v. Church of Scientology, 58 Cal. App. 3d 439, 443 (1976), n.1.
55. Interestingly, there was no cause of action for false imprisonment, though the court
found ample evidence of coercion, and no cause of action for invasion of privacy, though
the court found evidence that the confidences Wollersheim made in a confessional
setting were improperly disclosed.
56. Compare F. Conway &J. Siegelman, Snapping supra n. 14, at 166: “The Scientology
method...has no religious or spiritual pretensions.”
57. 3 Witkin,Cal. Procedure, Actions, &356, at 383(3d ed. 1985). The question of when he
discovered, or should have discovered, all of the elements of his causes of actions
against the church was a jury question, and the court of appeals was satisfied with their
finding that Wollersheims‟s discovery fell within the statutory period.
58. The court suggested this is still a question of lively debate. See Founding Church of
Scientology v. United States, 409 F.2d 1146, 1160-61 (1969) Founding Church of
Scientology v. Webster, 802 F.2d 1448, 1451 (1986).
59. Wollersheim, 212 Cal. App. 3d at 89l3.
60. Also, the court found no distinction between Scientology‟s policy of “disconnect” and the
“shunning” practiced by Jehovah‟s Witnesses and Mennonites. Where shunning isolates
one member of a group from the rest of the members, the disconnect policy isolates the
individual from his family outside the group. Since in Wollersheim‟s case the practice of
disconnect was coerced, the court escaped having to conclude whether to follow the law
in Paul v. Watchtower Bible &Tract Soc. of New York, 819 F.2d 875 (1987) (religion
cannot be held civilly liable to shunned former member because shunning is
39. Molko, 46 Cal. 3d at 1117.
40. Id. at 1118.
41. Id.
42. Id. at 1125. As to the church‟s cross-claim against the deprogrammers, the supreme
court found there was a triable issue of fact as to whether the deprogrammer was part
of an ongoing conspiracy to prevent church members from freely exercising their
religious beliefs through interstate travel, and thus subject to an injunction to prevent
future forcible deprogramming activities. Id. at 1127-8.
43. 213 Cal. App. 3d 729 (1989), cert. denied _U.S. _,110 S. Ct. 2168, 109 L. Ed. 3d 498
(1990).
44. See Denniston, Supra n. 21.
45. George, 213 Cal. App. 3d at 757.
46. Pen. Code &236.
47. Pen. Code &237.
48. George, 213 Cal. App. 3d at 766.
49. Cult apologists argue the entire brainwashing theory must be predicated by force or
threat of force. Telephone interview with Ford Greene, August 1, 1990.
50. George, 213 Cal. App. 3d at 729
51. Robin‟s libel claim was not supported by the appellate court, because the statements in
the “official position” circulated by the Krishnas that were not true were merely opinion.
The court did find evidence to support the jury‟s finding that the document was
defamatory as to the mother, since the document alleged physical abuse of her daughter
as a reason for her leaving home, a statement of fact determined to be false. Robin‟s
wrongful death claim also succeeded, as Marcia had warned the Krishna leadership of
her husband‟s heart condition but the Krishnas had disregarded the foreseeable harm
and persisted in hiding Robin from the family.
52.Wollersheim v. Church of Scientology, 212 Cal. App. 3d 872, 879 (1989), cert. denied,
110 S.Ct. 1937, 109 L.Ed. 2d 300 (1990).
53. These sessions are designed to train an individual to have no emotional response
whatever to verbal stimuli. For a detailed description of this process and its effects, see
F. Conway &J. Siegelman, Snappping, supran. 14, at 161-68.
54. See Allard v. Church of Scientology, 58 Cal. App. 3d 439, 443 (1976), n.1.
55. Interestingly, there was no cause of action for false imprisonment, though the court
found ample evidence of coercion, and no cause of action for invasion of privacy, though
the court found evidence that the confidences Wollersheim made in a confessional
setting were improperly disclosed.
56. Compare F. Conway &J. Siegelman, Snapping supra n. 14, at 166: “The Scientology
method...has no religious or spiritual pretensions.”
57. 3 Witkin,Cal. Procedure, Actions, &356, at 383(3d ed. 1985). The question of when he
discovered, or should have discovered, all of the elements of his causes of actions
against the church was a jury question, and the court of appeals was satisfied with their
finding that Wollersheims‟s discovery fell within the statutory period.
58. The court suggested this is still a question of lively debate. See Founding Church of
Scientology v. United States, 409 F.2d 1146, 1160-61 (1969) Founding Church of
Scientology v. Webster, 802 F.2d 1448, 1451 (1986).
59. Wollersheim, 212 Cal. App. 3d at 89l3.
60. Also, the court found no distinction between Scientology‟s policy of “disconnect” and the
“shunning” practiced by Jehovah‟s Witnesses and Mennonites. Where shunning isolates
one member of a group from the rest of the members, the disconnect policy isolates the
individual from his family outside the group. Since in Wollersheim‟s case the practice of
disconnect was coerced, the court escaped having to conclude whether to follow the law
in Paul v. Watchtower Bible &Tract Soc. of New York, 819 F.2d 875 (1987) (religion
cannot be held civilly liable to shunned former member because shunning is
