If a clergyman is to be granted complete immunity to say whatever he believes, or to take any action which he believes best for his church or his congregation, then eventually either our concept of separation of church and state will be destroyed or else by the very weight of the immunities and the inequities resulting therefrom the qualified privilege of the clergyman will be destroyed. The real question is not whether such a privilege exists or should exist, but at what point does the interference with the rights of the individual become so great as to be actionable. This is the sole question posed by this article.
Robert B. Dunsmore, Clergymen's Interference with Private Rights, 10 Clev.-Marshall L. Rev. 52 (1961)