In Tennessee, a notorious international church cult was sued for fraud. Cult leaders teach followers “the only way to avoid harm or death” is to turn over a substantial percentage of their assets. A couple gave and gave, but not enough and were expelled. A state appellate court decided judicial inquiry into whether there was “misrepresentation of a material fact” - required in a fraud case - requires evaluation of the validity of religious beliefs in violation of the free exercise of religion guaranteed by the first amendment.