Abstract
Nally v. Grace Community Church of the Valley ( 1 ), a case initially decided in California in 1984, has aroused considerable interest because it seemed to have the potential of ending the heated argument about whether clergy who practice counseling are protected from malpractice actions. One side in the debate contends that pastoral counseling is a religious activity; hence it is protected from malpractice claims by the First Amendment to the Constitution. Others view pastoral counseling as a secular activity and insist that its practitioners be held to a standard of care. In 1987 the California Court of Appeal was forced to issue a new decision in the case narrowly addressing the liability of counselors (including clergy) who enter a counseling relationship with sui-
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