Conti v. Watchtower: California appellate court affirms Jehovah's Witnesses' civil liability for failing to supervise a known abuser during church 'field service'
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Appellate history
2015-04-13
Compensatory award affirmed; punitive award reversed (duty-to-warn rejected, duty-to-supervise upheld).
Record class
Core record
Evidence status
Civil finding
Authority role
congregation elders, religious headquarters with policy authority
Organization
Watchtower Bible and Tract Society of New York, Inc., North Fremont Congregation of Jehovah's Witnesses
Archive classification
This is the archive's application of its published inclusion test. The cited record appears below.
The abuser's unsupervised access to the plaintiff arose through 'field service,' a church-sponsored door-to-door ministry conducted under elder authority within a close-knit congregation whose members were counseled to associate only with co-religionists; the court held the organization could be liable for failing to limit and supervise that access.
- Pastoral or clerical authority
- Institutional obedience or isolation
Evidence structure
Proceedings
2015-04-13 · civil appeal — compensatory liability affirmed
California Court of Appeal, First District. The California Court of Appeal affirmed compensatory-damages liability against the congregation and Watchtower for failing to limit and supervise a member (Jonathan Kendrick) whom elders knew had molested a child, and who abused the plaintiff during 'field service'; the punitive-damages award tied to a duty-to-warn theory was reversed.
Documented coercion mechanisms
- church-sponsored unsupervised access (field service)
- congregational insularity
Cited record
Sources
- appellate court civil opinion Conti v. Watchtower Bible & Tract Society of New York, Inc., 235 Cal. App. 4th 1214 (2015).
The California Court of Appeal opinion affirms the compensatory-damages liability of the congregation and Watchtower for failing to supervise a known abuser during church field service, and reverses the punitive-damages award.
Source provenance
Source access and integrity log
This log records source retrieval and file integrity. It does not mean that an automated process independently confirmed every statement in the source.
- Source and tier basis
- https://www.courtlistener.com/opinion/2793343/conti-v-watchtower-bible-tract-society-of-new-york-inc/ Corpus classification: appellate-court; evidentiary role: civil-opinion. SHA-256 e3b0c44298fc1c149afbf4c8996fb92427ae41e4649b934ca495991b7852b855
- Retrieval
- 2026-07-20 · Preserved
- Bound by Fear automated source-preservation ledger
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Related record
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