It is a deviation from the standards of performance applicable to the professional service in 'question. See Sanzari v. Rosenfeld, 34 N.J. 128, 134-35, 167 A.2d 625 (1961). A major distinction between the “usual negligence case” and a case of professional negligence is that in the latter, the standard of care ordinarily must be established by expert testimony. Id. at 134-35, 167 A.2d 625. Regarding the risk of undue entanglement in ecclesiastical affairs arising out of a case of clergy malpractice, we share the concerns of those courts that have addressed the issue. We are, however, persuaded that those concerns are overstated in circumstances, such as the present case, involving a cleric’s sexual misconduct. Cf. Welter v. Seton Hall Univ., 128 N.J. 279, 291, 608 A.2d 206 (1992) (<HOLDING>). But cf. DeBose v. Bear Valley Church of
holding the defendants claim that he was denied the right to testify was appropriate for direct review when the record was adequately developed to permit full consideration of the defendants claim the pertinent facts were undisputed a pcr hearing was not necessary to resolve a factual dispute and would not aid in the application of the law and the defendants claim was presented not as an ineffective assistance of counsel claim but rather as an error committed by the trial court in excluding the defendants testimony which was not an appropriate basis for an ineffective assistance of counsel claim holding that defendants failed to demonstrate that an employment dispute turned on issues of doctrine or polity and therefore the trial court properly exercised jurisdiction and the sincerity of defendants religious beliefs was not legally relevant to their jurisdictional claim holding that although of course an employee is not required to modify his religious beliefs a reasonable accommodation need not be on the employees terms only holding that the defendants motion for discharge was premature and thus properly denied by the trial court holding that statements based upon defendants beliefs are actionable because there was evidence that the defendants were aware of undisclosed facts that seriously undermined the accuracy of their alleged opinions or beliefs