Inc., 911 F.2d 1082, 1083 (5th Cir.1990) (stating "the 'correct' interpretation of the life of Christ ... is not a justiciable question before a federal court”). Some treat the matter as an affirmative defense to liability. See In re: Roman Catholic Archbishop of Portland in Or., 335 B.R. 842, 849, 853 (Bankr.Or.2005) (granting summary judgment on affirmative defense of lack of subject-matter jurisdiction); Brazauskas v. Fort Wayne-South Bend Diocese, Inc., 796 N.E.2d 286, 290 (Ind.2003) (stating "pleading an affirmative defense like the Free Exercise Clause may under certain facts entitle a party to summary judgment”). But the majority of courts broadly conceptualize the prohibition as a subject-matter bar to jurisdiction. See, e.g., Tilton v. Marshall, 925 S.W.2d 672, 682 (Tex.1996) (<HOLDING>); Bell v. Presbyterian Church, 126 F.3d 328,
holding that act did not bar intentional infliction of emotional distress claim holding trial court abused its discretion in refusing to dismiss plaintiffs intentional infliction of emotional distress and related conspiracy claims and prohibiting court from exercising jurisdiction over them except to dismiss recognizing torts of intentional and negligent infliction of emotional distress recognizing the tort of intentional infliction of emotional distress holding that intentional infliction of emotional distress is a personal injury tort