The South Dakota Supreme Court ruled that statements made by a pastor to a denominational official concerning his wife's sudden death in a bathtub were not protected by the clergy-penitent privilege.
A Michigan court issues an important ruling-Smith v. Calvary Christian Church, 1998Â WLÂ 842259Â (Mich. App. 1998) [Invasion of Privacy, Church Members,The Establishment Clause]