subject-matter jurisdiction over tort claims that are intertwined with ecclesiastical investigations or proceedings involving the employment or discipline of clergy. Ex parte Bole, supra. In Ex parte Bole, the plaintiff was a pastor emeritus of a church and the defen dant was a lay member of the church. 103 So.3d at 42. After the lay member made statements to the church’s hierarchy (“the Conference”) concerning the pastor, the Conference initiated an investigation that ultimately led to the pastor being asked to refrain from further activities with the church. 103 So.3d at 48. The pastor sued the lay member, alleging defamation, invasion of privacy, and intentional infliction 2d 302, 533 N.W.2d 780, 790 (1995) (same). “Federal courts: Dausch v. Rykse, 52 F.3d 1425, 1427 (7th Cir.1994) (<HOLDING>); Ayon v. Gourley, 47 F.Supp.2d 1246, 1250
holding that claim of breach of fiduciary duty against pastor for sexual relationship with parishioner during the course of pastoral counseling was tantamount to impermissible clergy malpractice claim holding that first amendment barred parishioners negligent hiring and supervision and breach of fiduciary duty claims against pastor and church for sexual contact that occurred between pastor and parishioner during the course of a counseling relationship holding that negligent retention and supervision claims based upon a pastors sexual contact with parishioners was barred by the first amendment holding that first amendment barred adults breach of fiduciary duty claim against pastor for actions that occurred when parishioner was a minor 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