parte Bole was a case of first impression; cases from other jurisdictions, however, support this Court’s rationale in Ex parte Bole. See, e.g., Seefried v. Hummel, 148 P.3d 184, 188 (Colo.App.2005) (“As relevant here, the court determined that the statements which gave rise to plaintiffs' claims were issued within the 'constitutionally protected context’ of the First Amendment of the United States Constitution because they occurred during a church meeting that concerned the ‘investigation, discipline and discharge of Richard and James Seefried.' The court, consequently, declined to exercise subject matter jurisdiction over these claims. Plaintiffs contend that this was error as a matter of law. We agree with the trial court.”); Yagg od, 237 Mich.App. 567, 603 N.W.2d 816, 822-23 (1999) (<HOLDING>); Minnesota: Mulinix v. Mulinix, No. C2-97-297
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 negligence claims against clergy member and religious organization for alleged sexual relationship during the course of a counseling relationship were 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 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 adults breach of fiduciary duty claim against pastor for actions that occurred when parishioner was a minor