In Gallagher v. Connell (2004) 123 Cal.App.4th 1260, a parish priest assisted an elderly member of the parish with her financial affairs and thereafter became the primary beneficiary and successor trustee of the parishioner's living trust. With respect to the controversy that arose from this situation, the court stated, "We have found no case which has held simply being a member of the clergy makes one an all-purpose public figure for purposes of a defamation action. We hold it does not." (Gallagher, supra, 123 Cal.App.4th at p. 1273.) The court noted that Gallagher was "no Jerry Falwell, Jesse Jackson, or Louis Farrakhan." (Ibid.) There was no evidence that Gallagher had ever sought or received notoriety or public attention by reason of his position or achievements. (Ibid.) The court further concluded that Gallagher was not a limited purpose public figure because he did not thrust himself into the public controversy over who should be the successor trustee and beneficiary under the parishioner's trust. (Ibid.)