97 churches brought a defamation suit in Texas against the publisher of The Encyclopedia of Cults and New Religions. The book labeled the churches as “cults”defined as organizations involved in, among other things, denial of medical assistance, drug smuggling, prostitution, rape, murder, and child molestation. A Texas appellate court ruled for the publisher. The truth or falsity of the statement depended upon one's religious beliefs, which, under the establishment clause of the first amendment, could not be tried in a court of law.