Coverage and Liability Issues in Sexual Misconduct Claims

CONNECTICUTOtherSexual abuse perpetrated by a Catholic priest is outside the scope ofhis employment and therefore the church may not be held vicariouslyliable for such acts. Beach v. Jean, 746 A.2d 228 (Conn. Super. Ct.1999); Doe v. Hartford Roman Catholic Diocesan Corp., 716 A.2d 960(Conn. Super. Ct. 1998); Nutt v. Norwich Roman Catholic Diocese etal., 921 F. Supp. 66 (D. Conn. 1995); Cf. Mullen v. Horton, 700 A.2d1377 (Conn. App. Ct. 1997) (Religious employer held vicariously liablefor employee’s abuse of adult during counseling sessions becauseemployer may have benefited from the illegal acts).The First Amendment does not bar claims against religious institutionsfor negligent hiring, training, retention and supervision of clergy.Martinelli v. Bridgeport Roman Catholic Diocesan Corp., 196 F.3d409 (2d Cir. 1999); Rosado v. Bridgeport Roman Catholic DiocesanCorp., 716 A.2d 967 (Conn. Super. Ct. 1998); Doe v. Hartford RomanCatholic Diocesan Corp., 716 A.2d 960 (Conn. Super. Ct. 1998); Nuttv. Norwich Roman Catholic Diocese et al., 921 F. Supp. 66 (D. Conn.1995).– 11 –