“Pastor turns his parishioner into a zombie”
A 1988 court held that persons need not be turned all the way into zombies in order to find that undue influence has been exerted upon them.
The Court explains:
While there is no one factor which establishes undue influence, considered together, the facts found by the bankruptcy court satisfy the legal requirements. Stevens was Elizabeth Dovydenas’ pastor. She was a loyal and devoted member of the church. The bankruptcy court found that Stevens told her that her money granted her special status. If he did not inculcate, then he reinforced her beliefs that her gifts could alter events in the world such as curing Mrs. Stevens’ migraine headaches. The danger of a confidential relationship is not confined, as appellant claims, to situations in which the pastor turns his parishioner into a zombie or automaton. Rather, the law recognizes the danger of undue influence in the pastor/parishioner relationship because of the trust instilled. [citation omitted]
This case arose after Elizabeth Dovydenas, an heiress reportedly worth 19 million dollars, gave over 6 million to Carl Stevens as chief operating officer of an evangelical church named The Bible Speaks. When she tried to get it back, the church entered bankruptcy, but the bankruptcy court ordered the money returned.
The bankruptcy court found that during that time, “Stevens told her, in substance, on numerous occasions that: giving money to the church was her primary mission on earth; all she needed to live on was $ 1 million, and the rest should be given to the church; she should not be influenced by her husband, or her parents, sisters or advisors, because they have not been born again through the church and are therefore controlled by the Devil, and her money gave her power to release God’s judgment in order to effect miracles.”
On appeal, this court affirmed the bankruptcy court’s judgment:
Having found the bankruptcy court’s conclusion that debtor-appellant TBS exerted undue influence which resulted in gifts of $ 6,581,356.25 by the claimant-appellee is not clearly erroneous, the judgment of the bankruptcy court dated May 19, 1987 is hereby AFFIRMED. Appellant’s motion for summary judgment dated February 9, 1987 is DENIED.