A woman in Ohio was seduced by a priest and bore his child. The church counseled the woman to forgive the priest and consent to adoption. Many years later the woman sued the church for failing to properly supervise the priest. The church raised the statute of limitations - too much time had elapsed. The woman argued the church cannot force her slience and then benefit from the passage of time. The church countered: the free exercise clause of the first amendment prohibits inquiry into church counseling because it is a matter of theology. The church lost. Courts are permitted to inquire into purely secular actions by a church. Avoidance of scandal - and child support - is secular and not religious.