activities may be infused with doctrinal and spiritual content, though the cleric is providing secular services regarding marital discord, depression, anxiety and parent-child conflicts. We conclude that one test to determine whether a cause of action against a cleric is cognizable in civil courts is whether adjudication of the claim requires an evaluation of dogma or ritual, or other matters of purely ecclesiastical concern. In the present case, it is unlikely that defendants will assert that sex with a counselee by a pastoral counselor is sanctioned by or somehow involves tenets of the Episcopalian church, or would otherwise create an entanglement with religious beliefs or rituals of First Amendment concern. See Strock v. Pressnell, 38 Ohio St.3d 207, 527 N.E.2d 1235 (1988) (<HOLDING>). Moreover, there is a bright line between
holding that first amendment barred negligent supervision claim against a church regarding sexual relationship between adult parishioner and priest during the course of a marital counseling holding that the first amendment was not available as a defense in action against minister who had sexual relations with plaintiffs wife while counseling the couple regarding their marital difficulties holding that first amendment barred adult parishioner who engaged in sexual relationship with priest during the course of pastoral counseling from bringing intentional infliction of emotional distress negligence and breach of fiduciary duty claims holding that first amendment barred consideration of negligent supervision claim against diocese for sexual relationship between adult parishioner and priest while the priest was counseling the parishioner in his position as a hospital chaplain recognizing cause of action for damages against federal agents acting under their authority who allegedly violated plaintiffs fourth amendment rights