Scientology’s Frankenstein Clause: The Stitched Monstrosity Of Religious Arbitration Contracts

ultimately upheld a decision for the Church, finding no violation. 58 There has since been a steady stream of ex-members ready to accuse the Church of various wrongs and harassment. 59 However, these plaintiffs have seldom seen the inside of a courtroom.Headley was resolved at the Ninth Circuit in 2012.The following year, Luis Garcia brought his fraud and breach of contract suit against the Church and was compelled to arbitrate his claims before Scientologists in accordance with the arbitration procedures of the Church of Scientology: the first proceeding of its kind. 60 B. Garcia v. Church of Scientology: The First ArbitrationLuis Garcia joined the Church of Scientology in 1982. 61 Over the course of twenty-two years, Luis signed at least twenty written enrollment agreements with the Church each time he engaged the church for services, sometimes signing multiple agreements in a week. 62 Amongst the artful clauses in the contracts were such statements as "I . . .recognize, acknowledge and agree that. . . .Scientology is a religion, the Church is a church of the Scientology religion, and all the services and activities of the Scientology religion are exclusively religious in nature" 63 and "[m]y freely given consent to be bound exclusively by the discipline, faith, internal organization, and ecclesiastical rule, custom, and law of the Scientology religion in 58 See id. at