Caekaert v. Watchtower Bible and Tract Society of New York, Inc.

CourtDistrict Court, D. Montana
DecidedFebruary 6, 2024
Docket1:20-cv-00052
StatusUnknown

This text of Caekaert v. Watchtower Bible and Tract Society of New York, Inc. (Caekaert v. Watchtower Bible and Tract Society of New York, Inc.) is published on Counsel Stack Legal Research, covering District Court, D. Montana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Caekaert v. Watchtower Bible and Tract Society of New York, Inc., (D. Mont. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MONTANA BILLINGS DIVISION

TRACY CAEKAERT and CAMILLIA MAPLEY, CV 20-52-BLG-SPW Plaintiffs, ORDER Vs. WATCHTOWER BIBLE AND TRACT SOCIETY OF NEW YORK, INC., and WATCH TOWER BIBLE AND TRACT SOCIERY OF PENNSYLVANIA, INC. Defendants. Before the Court is Plaintiffs Tracy Caekaert and Camillia Mapley’s Motion

for Sanctions. (Doc. 287). Plaintiffs seek sanctions against Watchtower Bible and

Tract Society of New York, Inc. (“WTNY”) pursuant to Federal Rule of Civil

Procedure 37(b)(2)(A) for allegedly violating the Court’s August 24, 2021 Order Granting Plaintiffs’ Motion to Compel Jurisdictional Discovery Responses (Doc. 85, hereinafter “Order”). (Doc. 287). Plaintiffs contend WTNY violated the Order’s requirement that WINY “fully and completely” respond to Interrogatories 9 and 15

because WINY omitted substantial information concerning the Jehovah’s Witnesses Governing Body and the relationships among several of the organization’s entities that Plaintiffs later discovered on their own. (Doc. 288 at 1— 10). As for the appropriate remedy if sanctions are warranted, Plaintiffs ask the

Court to prohibit WINY from presenting certain defenses and evidence. (Jd. at 16— 17). WTNY filed a response opposing the motion on various procedural grounds and because it claims its answers complied with the Order. (Doc. 290). It also

objects to the proposed sanctions as unsupported by the evidence and

“disproportionate to any perceived inconsistencies in the descriptions of [the] religious entities.” (Jd. at 26). With the permission of the Court, Defendant Watch Tower Bible & Tract Society of Pennsylvania, Inc. (“WTPA”) also filed a response. (Doc. 294). WIPA

did not take a position on the merits of the sanctions but opposed the imposition of

Plaintiffs’ proposed remedies that implicate WTPA. (Jd. at 2). WTPA argues such

sanctions would improperly restrict WTPA’s defenses because WTPA is a non-party to the sanctions motion. (Jd. at 3-4). If the Court imposes the requested sanctions, WTPA urges the Court to remove any references to WIPA. (Id.). For the following reasons, the Court grants Plaintiffs’ motion as to the allegation that WINY failed to comply with the Order and denies Plaintiffs’ motion

as to the requested remedy. Instead of prohibiting WTNY from presenting certain

defenses and evidence, the Court will order certain designated facts as established and impose monetary sanctions. I

I. Background The origin of the parties’ dispute over WINY’s answers to Interrogatories 9

and 15 is outlined in detail in the Background section of the Order. (Doc. 85). The

Court adopts the Order’s recitation of the facts and will reiterate only those relevant details. On June 22, 2020, WTPA filed a Motion to Dismiss for Lack of Jurisdiction alleging that the Court lacked personal jurisdiction over it. (Doc. 13). The Court found the facts bearing on the question of jurisdiction were controverted and ordered jurisdictional discovery. (Doc. 32). WTPA withdrew its motion to dismiss on November 5, 2021. (Doc. 94). During the jurisdictional discovery and before WTPA withdrew its motion, Plaintiffs served a number of interrogatories on WITNY and WTPA, including Interrogatories 9 and 15. Interrogatory 9 asked: “Identify what the governing body does, where it is located, what it is responsible for, how it makes decisions, etc.?” (Doc. 288-1 at 4). In its original set of answers, WINY objected to Interrogatory 9, then, without waiving its objection, responded: The Governing Body is a small group of spiritually-mature Christians who provide spiritual guidance to Jehovah’s Witnesses worldwide. The Governing Body follows the pattern set by “the apostles and elders in Jerusalem” in the first century, who made important decisions on behalf of the entire Christian congregation. (Acts 15:2) Like those faithful men, the members of the Governing Body are not leaders of Jehovah’s Witnesses. The Governing Body serves in Warwick, New York, U.S.A.

(Id. at 4—5). Interrogatory 15 asked: “Please set forth your description of the relationships between the following: Governing Body, WTPA, WTNY, United States Branch Office, United States District Offices, United States Circuit Offices, and local Kingdom Halls/congregations (including whether any of these bodies oversee or direct, in any way, the activities of any other of these bodies.)” (/d. at 6). In its original set of answers, WINY objected to Interrogatory 15, then, without waiving its objection, responded: WTNY is a not-for-profit corporation formed in 1909 under the laws of State of New York, U.S.A. It is used by Jehovah’s Witnesses in the United States to print Bibles and Bible-based literature. Some of that literature is used in connection with ministry done by Jehovah’s Witnesses, again in connection with Jesus’ commission in Matthew 28:19, 20. WTPA is a nonprofit corporation formed in 1884 under the laws of the Commonwealth of Pennsylvania, U.S.A. It is used by Jehovah’s Witnesses to support their worldwide work, which includes publishing Bibles and Bible-based literature. Congregations form for the purpose of allowing Jehovah’s Witnesses and others interested in attending their meetings to gather together to worship God. At their own choice, congregations may form corporations or trusteeships to own property used as Kingdom Halls (meeting places). Those that do not form a corporation or trusteeship typically remain unincorporated associations. Each legal entity is distinct from one another. The United States Branch Office of Jehovah’s Witnesses is a religious construct that cares for the spiritual interests of Jehovah’s Witnesses in the United States. It has no legal or corporate control over any entity used by Jehovah’s Witnesses. The Governing Body of Jehovah’s Witnesses is an ecclesiastical group of men who care for the spiritual interests of Jehovah’s Witnesses worldwide. It has no legal or corporate control over any entity used by

Jehovah’s Witnesses. WINY is unaware of any “United States District Offices” or “United States Circuit Offices” associated with the faith of Jehovah’s Witnesses. (Id. at 6-7) Plaintiffs filed a motion to compel arguing that WINY’s answers were non-

responsive. (Doc. 56). The Court found, in part, that WINY’s initial answers to

Interrogatories 9 and 15 were “vague to the point of non-responsive” and ordered

WTNY to “fully and completely respond.” (Doc. 85 at 11-12). The Court awarded Plaintiffs $22,631.80 in attorneys fees and costs, in part because of WTNY’s failure

to adequately respond to Interrogatories 9 and 15. (/d. at 18; Doc. 93). WTNY served its supplemental answers on September 21, 2021. (Doc. 288- 1). As to Interrogatory 9, WINY reiterated its objection and, without waiving the objection, responded: WTNY further responds that it is not the Governing Body of Jehovah’s Witnesses, but upon information and belief, the Governing Body provides spiritual guidance and direction to all Jehovah’s Witnesses, including, but not limited to, setting forth the scriptural beliefs and practices of the faith in conformance with the model set by first century Christians as recorded in the Bible. The Governing Body does not direct the day-to-day affairs of any congregation of Jehovah’s Witnesses but, during the time period in question, experienced elders in New York (members of the religious order) acknowledged the appointment of congregation elders and ministerial servants. Acknowledgement of these appointments was communicated to congregations by WINY. at 5).

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Caekaert v. Watchtower Bible and Tract Society of New York, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/caekaert-v-watchtower-bible-and-tract-society-of-new-york-inc-mtd-2024.