Molko v. Holy Spirit Assn

In Molko v. Holy Spirit Assn. (1988) 46 Cal.3d. 1092, evidence was offered that recruiters for the Unification Church (Church) knowingly misrepresented the Church's identity to Molko, intending to induce him to associate with them, participate in Church activities, and later join the Church. By the time the Church finally disclosed its identity, its agents had brainwashed Molko so effectively that he was unable to decide not to join. (Id. at pp. 1108-1109.) The court held the evidence was sufficient to raise a triable issue of fact and deny summary judgment for the Church: "The Church's continued deceptions might well be seen as conduct breaching plaintiff's trust in the integrity of those who were promising to make their lives more meaningful. So viewed, the Church's actions might well constitute an abuse of 'a relation or position which gives the Church power to damage plaintiff's interest.' " (Id. at pp. 1122-1123.)