Scientology and the European Human Rights Debate:
A Reply to Leisa Goodman, J. Gordon Melton, and the European Rehabilitation Project Force Study

TABLE OF CONTENTS 

1) Introduction

2) New RPF Information

3) The Rehabilitation Project Force and Human Rights Violations

4) GordonMeltonon the Sea Organization

5) The European Rehabilitation Project Force Study

6) Goodman's Failure to Protect Scientology's Children

7) Character Aspersions

8) Did Not Say It; Did Not Do It; Not Guilty of It

9) Correcting the Facts

9.1) Scientology and the Demise of the Cult Awareness Network
9.2) Scientology's Own Criminality

10) Goodman's Portrayal of Critics

11) Scientology's Secret Agreement with the Internal Revenue Service

12)  Proof, Documentation, and Evidence

13) Scientology's Problems in Germany

14) Conclusion

1) Introduction

 At stake in the European human rights debate over Scientology is the legitimacy of various governmental responses to the organization that limit, and potentially prevent, its activities and those of its members. By any means, at all costs, Scientology must portray itself as an aggrieved party whose rights are being trampled by officials who are fostering bigotry, discrimination, rabid secularism, and denominational protectionism of historic faiths. Seen in this context, my lengthy and detailed publications about Scientology's near-certain human rights violations cannot go unchallenged by the organization and its defenders. Most serious are my conclusions that Scientology operates a forced labour and re-education program against reputedly delinquent members of its 'elite' Sea Org(anization)-a program that has included teenagers and children as young as twelve years old (Kent 1999c: 9). Called the Rehabilitation Project Force (RPF), this program, I concluded, fits social scientific definitions of brainwashing efforts (Kent 2000; 2001a; b). The program should be (and is) of particular concern for Europeans because its totalitarian nature harkens back to other anti-democratic ideologies that they have witnessed firsthand. 

 Leisa Goodman's response (Goodman 2001) to my earlier European human rights article in this journal (Kent 2001c) is the appropriate venue to present Scientology's perspective on the human rights debate, since a public arena is far preferable than some of the behind-the-scenes 'operations' that I have suffered in the past at Scientology's hands. (I will discuss some of them in a moment, since these attacks revealed a great deal about the character of the organization and its leaders). Part of Scientology's reactive strategy against the issues that I raise seems to be to attack my professional reputation in a manner that may diminish my reputation (and by extension, my academic credibility). 

 Related to Goodman's critique of my work is a presentation (by independent scholar J. Gordon Melton) about the allegedly religious nature of Scientology's highly committed Sea Org(anization) in which the RPF operates (Melton 2001). If the RPF is little different from existing worship and/or recuperative programs operating within normative religious organizations, then governments have no legitimate bases for intervention against Scientology by claiming that its members are abuse victims. Melton's strategy seems to be to dispute the accuracy of my scholarship while offering in its place a religious interpretation of events and social structures that I have (or likely would) consider to be primarily secular. Goodman's and Melton's criticisms complement each other, so I will address issues that both of them raise. I also must address a study conducted by Juha Pentikainen (of the University of Helsinki, Finland), Jugen F. K. Redhardt, and Michael York (of Bath Spa University College, England) about the RPF (Pentikainen, Redhardt and York 2002), since their positive findings about the RPF gloss over significant methodological and even ethical questions that must be addressed in any RPF study. (For the sake of convenience, I refer to this study as 'the European study.') In addressing these issues, however, I do not want readers to loose sight of the fundamental human rights issues that frame the large and important context in which these debates are taking place.

2) New RPF Information

 For the sake of argument, let us say (for the moment) that my scholarship is as unprofessional and biased as Goodman and Meltonclaim. For this exercise, let us say that my work on issues related to human rights and Scientology is seriously flawed, and that my lengthy, multiply-sourced, and heavily documented studies on the RPF are not worth the paper that they are printed on. My detailed study of the RPF determined that the program "put coerced participants through regimes of harsh physical punishment, forced self-confession, social isolation, hard labour, and intense doctrinal study, all as part of leadership-designed efforts to gain members' ideological commitment," (Kent 2000: 9), but let us put this conclusion aside. For the moment, take all of my RPF research and place it on the shelf so that we can examine newer RPF information that has reached the public eye. 

 Apparently catalyzed by my Hamburg-published RPF study, Danish newspaper reporter Pierre Collignon wrote four newspaper articles on the RPF in Copenhagen in mid-January 2001. Not having to gain clearance (as should academics) for interviewing human subjects, Collignon interviewed a Scientologist who had been in the RPF program for eighteen months. Perhaps more importantly, Collignon also gained unprecedented access to the reputedly sacred scriptures that outline the restrictions under which RPF inmates must operate. While I will not repeat all of his findings, much of what he discovered will be useful for measuring the accuracy of some parts of my own research.

 Collignon summarized Scientology's newest RPF documents-documents that I never have seen-and his summary shows that the Scientology organization places the following conditions on people in the program:

• They are not to see their families.
• They are not to address other people.
• They are not to leave Scientology's buildings on their own.
• They are not to drive a car.
• They are to wear a black armband and live segregated from the other Scientologists.
• They are to run instead of walk (Collignon 2001a).

The German Scientologist whom Collignon interviewed had not seen his wife during the entire eighteen months in which he was in the RPF, and for thirteen of those months he was in Los Angeles (along with approximately 150 people) doing gardening work, reading, and auditing (Collignon 2001b). All of his reading had to have been Scientology materials, since people in the RPF were prohibited from bringing in novels "or any other forms of entertainment . . ." (Collignon 2001a). For his labour during this period, he received only one-quarter of his usual pay, and all the while he was forbidden to "initiate written or verbal communication to people outside the RPF" (Collignon 2001a).

 From this summary of Collignon's findings, we now can see the deficiencies of my earlier scholarship. When I had written about the RPF in articles against which Goodman andMeltonhave responded, I had underestimated the harshness of current operations. Elements of the program now are more abusive than my research would have predicted! While much of what I had written coincided with Collignon's findings (and other aspects of my work extend beyond Collignon's research), I nonetheless had RPF salaries rising from one-quarter to one-half the normal rate as members progressed in the program. Collignon, however, only mentioned that RPFers received one-quarter of their usual remuneration. Most significantly, people on the newer RPF program are forbidden to have contact with their families, which is a dramatic escalation beyond the earlier rules. Indeed, the German Scientologist who had been on the RPF for eighteen months accepted the prohibition against family contact as simply being "'part of the game'" (quoted in Collignon 2001b). The issue that Collignon verged on addressing is the impact that these family-contact prohibitions likely would have on children of RPFers. As he indicated, "[t]he rules recently have been tightened with a clause forbidding any connection with the family. Previously, Scientologists on the RPF could be allowed to meet their spouse or children once a week" (Collignon 2001c).

3) The Rehabilitation Project Force and Human Rights Violations

 Scientology's restriction on RPFers from having contact with family members (including children) appears to be a flagrant violation of Article 8 of The 1950 European Convention for the Protection of Human Rights and Fundamental Freedoms. The first paragraph of that article states, "Everyone has the right to respect for his private and family life, his home and his correspondence" (in Janis, Kay, and Bradley 1995: 471). Similarly, the twelfth article of the Universal Declaration of Human Rights requires, "No one shall be subjected to arbitrary interference with his privacy, family, home or correspondence, nor to attacks upon his honour and reputation. Everyone has the right to the protection of the law against such interference or attacks" (in Janis, Kay, and Bradley 1995: 507; see Kent, 1999c: 11). Indeed, the United Nations' Declaration of the Rights of the Child (proclaimed by General Assembly resolution of 20 November 1959) states:

The child, for the full and harmonious development of his [sic] personality, needs love and understanding. He shall, wherever possible, grow up in the care and under the responsibility of his parents, and, in any case, in an atmosphere of affection and of moral security; a child of tender years shall not, save in exceptional circumstances, be separated from his mother (United Nations General Assembly 1959: Principle 6).

Seen in the context, therefore, of several international resolutions, Scientology's prohibition of family contact among members in the RPF appears to be a serious human rights violation, which is an argument that I made in my lengthy RPF study (Kent 2000: 51). I also made a similar argument about the human rights violations inherent in the dramatic drop in remuneration and prohibitions against holidays that RPF members (arbitrarily) face, and I raised a number of additional human rights issues that are in keeping with Collignon's new evidence (Kent 1999c: 11; 2000: 51).

 It is not enough for Scientology to require that Sea Org members such as Franz Stoeckl "'sign [a statement] that you're doing it voluntarily and that you can leave at any time,'" as Scientology's European spokesperson, Gaetane Asselin, insisted (quoted in Collignon 2001c). The Scientology organization must be prohibited from demanding that these and other restrictions apply to its members under any circumstances, regardless of what internal status (including RPFer) they hold. Again, the European Convention is clear: "The enjoyment of the rights and freedoms set forth in this Convention shall be secured without discrimination on any ground such as sex, race, colour, language, religion, political, or other opinion, national or social origin, association with a national minority, birth or other status" (in Janis, Kay and Bradley 1995: 472 [Article 14]). Even if it were true, as Goodman andMeltonassert, that the RPF resembles programs in "other" religions, Scientology still does not have the right (under international agreements) to restrict members' contact with their families. Clear and certain as this legal point may be, one must not forget the human cost, especially regarding children, for family members who toil (in one case that Collignon uncovered, for five years) under these restrictions.  

 Indeed, the reality in which this organization places doctrinal adherence over individual needs is identical to one aspect of thought reform or brainwashing programs that psychiatrist Robert J. Lifton identified forty years ago in the context of the communist Chinese. Writing about one aspect of ideological totalism or brainwashing programs (Lifton 1961: 420, 435) that he called "Doctrine Over Person," Lifton spoke about the tendency for brainwashing groups to demand "the subordination of human experience to the claims of doctrine" (Lifton 1961: 430). Such groups "demand that character and identity be reshaped, not in accordance with one's special nature or potentialities, but rather to fit the rigid contours of the doctrinal world. The human is thus subjugated to the ahuman" (Lifton 1961: 431), which in the circumstances of the RPF means the subjugation of normal spousal or family contact to the totalistic possessiveness of a "greedy institution" (see Coser 1974). On this issue alone, no wonder governments such as France and Germany are scrutinizing Scientology so carefully.

 Considerable wonder exists, however, about how J. GordonMeltonfailed to realize the abusive implications of the RPF's current policies on children of RPF inmates. Perhaps he did not read it or perhaps it did not yet exist, since Collignon (who conducted his research after Melton) indicated that the policy forbidding RPFers from having contact with family members was a fairly recent addition. In any case,Meltonmade no mention of this restrictive policy, stating instead that--in preparation for his RPF study--he reviewed "the set of 30 documents on the RPF written by Hubbard as Flag Orders between 1974 and 1985 . . ." (Melton 2001: n. 49). He did admit, however, that "[t]he hardest hit by the program are married couples, as they have little contact while one of them is in the program. They are encouraged to write regularly, but have only infrequent face-to-face contact" (Melton 2001: 15). For whatever reason, Melton failed to consider the impact of parental deprivation on children (not to mention on the parents themselves), and he did not indicate when RPF inmates had time to write their family members during their busy, monitored days. Keep in mind, too, that the deprivation of parental and/or spousal contact goes on for months if not years. AsMeltonhimself concluded, "[o]ne year appears to be the minimum" amount of time that one stays in the RPF, but he "interviewed one person who had been in for approximately three years" (Melton 2001: 16). For these reasons alone, I am mystified howMeltoncould conclude, "I have, however, found no evidence of any pattern of abuse as a common element of life in the RPF" (Melton 2001: n. 60). Just on the issue of family contact, this evidence is within the very information that he cited.

 The issue of authorship of the RPF documents is on some importance, especially since the ones that I have seen were approved by Hubbard but not necessarily written by him. If in fact Hubbard actually wrote the RPF documents asMeltonindicated, then (as emanations from the group's founder) they are among Scientology's self-identified "sacred" scriptures. I am very surprised, therefore, thatMeltoneven would avail himself of these documents, since Scientology has restricted their circulation only to high-level, eligible members. In an article in which I and a co-author expressed concerns aboutMeltonand other academics supporting Scientology's efforts to maintain doctrinal secrets by restricting access to key documents (Kent and Krebs 1998b: 42-43),Meltonresponded by stating:

Not just sociologists, but all researchers-whether they be anthropologists, psychologists, or religious scholars-have to make some personal decisions about how they as outside observers and unbelievers will relate to what is considered most holy by the group under scrutiny. This is an issue about which we disagree. In the case of the Church of Scientology, whose life is structured into a series of ascending steps, the teachings of their higher levels (like most esoteric groups) are held to be their most sacred. While I would like to be privy to those teachings, they have not chosen to share them with me, and those who currently possess copies and/or have attempted to publish them abroad, have been working ultimately from copies taken without permission from the church. Although I have no great love for the Church of Scientology, I respect its right to establish a holy realm for its members (Melton 1999: 17).

PresumablyMeltonhad in mind the battle over Scientology's upper-level "Operating Thetan" documents when he made this statement, but the RPF Flag Orders also are restricted and (if in fact they were Hubbard-written items as he claimed) presumably sacred documents. Having stated, in 1999, his respect for both Scientology's establishment of a holy realm for its members and its identification of some documents as closed except to higher-level members,Meltonnow is basing scholarship on them. He appears to have changed his mind, therefore, about the propriety of scholars working with restricted items such as the Flag Orders.

4) GordonMeltonon the Sea Organization

 Melton's comments about the RPF appeared in the context of a larger study of the Sea Organization. The context that he hoped to create was one that framed the Sea Organization as a religious community, thereby making the RPF an(other) example of a system "whereby those who break the rules may make recompense and be integrated back into the life of the community" (Melton 2001: 12). He attempts to make his case, however, through analogy with the Trappists, Catholicism's Canon Law, and various Buddhist monastic traditions. He must use this tactic, however, because Scientology's own documents from the late 1960s and early 1970s about the creation and early operation of the Sea Organization ignore any religious claims and instead portray it primarily in managerial terms. 

 History (whichMeltonignores) provides the context for Hubbard's creation of the Sea Org in 1967 (Hubbard 1967). In December 1965, the State of Victoria in Australia "effectively outlawed Scientology and empowered the Attorney General to seize and destroy all Scientology documents and recordings" (Miller 1987: 254). In February 1966, the Australian Board of Inquiry into Scientology (conducted by Kevin A. Anderson, QC), issued its scathing report of the organization (calling it and its techniques "'evil'" identifying it as a "'serious threat to the community'" (quoted in Miller 1987: 252). That report stirred interest in England (where Hubbard was at the time). By April 1966, Hubbard was off to Rhodesia, hoping to find a favourable environment for Scientology's operation there. The government refused to renew his Temporary Residence Permit in mid-July, which forced him to leave the country (Miller 1987: 257-260). These problems simply compounded the hostility that Scientology received in the United States, epitomized by a massive raid in January 1963 by the Food and Drug Administration against the Scientology building in Washington, D.C. (Miller 1987: 247). One highly plausible interpretation, therefore, of Hubbard's creation of the Sea Organization and its ocean-going ships was that Hubbard wanted to escape the scrutiny of governments-an interpretation given credence by comments he made to a prominent Scientologist in late 1966 (Miller 1987: 262). In addition, Hubbard created the Guardian Office during this same period (on March 1, 1966), partly to provide his organization with an agency that could fight its critics.

 As reported by Roy Wallis, Scientology publications from this period identified that the Sea Org was "the research and management branch of the Church of Scientology" whose purpose was "to get ETHICS IN" to society at large (Wallis 1976: 140). The ethics that the Sea Organization was to get into society (through the management and expansion of Scientology's courses and 'technology') was a peculiar brand of morality that uniquely benefitted the organization. According to one of Scientology's dictionaries in its definition of "ethics," "the purpose of ethics is to remove counter intentions from the environment. And having accomplished that the purpose becomes to remove other intentionedness [sic] from the environment" (Hubbard 1976a: 179). In plain English, the purpose of Scientology ethics is to eliminate opponents, then eliminate people's interests in things other than Scientology. In this "ethical" environment, Scientology would be able to impose its courses, philosophy, and "justice system"-its so-called technology-onto society. The same definition of ethics, therefore, carries the claim, "[a]ll ethics is for in actual fact is [sic] simply that additional tool necessary to make it possible to get technology in. That's the whole purpose of ethics; to get technology in" (Hubbard 1976a: 179). Consequently, a 1998 article in the Scientology magazine dedicated to the Sea Organization, High Winds, stated (in bold, capital letters), "[i]n late December, 1969, LRH [L. Ron Hubbard] had written a Flag Ship Order in which he stated that 'THE SEA ORG IS PRIMARILY AN ETHICS ORGANIZATION'" (Church of Scientology International [CSI] 1998: 19).

 Getting ethics into society depended upon the proper use and management of Scientology's "technology" (Hubbard thought), so in 1970, he sent a memo to Sea Organization people stating:

We are a management company (operation) and we transport people of course.

Factually hundreds of companies of a commercial type use our technology and we get regular queries from them and have stacks of letters about this....

 Please believe me that is what we do, it is all we do and it doesn't need embroidery because it's true (Hubbard 1970).

Of course, as Scientology continued to develop its religious angle, largely in an effort to minimize societal scrutiny of its activities while receiving tax breaks, the organization needed to embroider early Sea Organization history and purpose. Melton's paper about it is a dramatic example of how sympathetic commentators can rewrite the past in order to fit the needs of the present, but that study's neglect of key documents from the late 1960s and early 1970s make his effort unconvincing.

5) The European Rehabilitation Project Force Study 

 Melton, like one of the authors of the European RPF study (Juha Pentikainen), has endorsed Scientology's religious claims (Pentikainen and Pentikainen 1996), and the organization utilizes these endorsements in its efforts to gain legitimacy. Moreover, the time-frame in which the authors conducted their studies coincided, and one supposes that this overlap in time (and one location) was coincidental. Melton conducting his RPF interviews of "more than a dozen" people on the program in Los Angeles, Clearwater, and Copenhagen during the Summer and Fall of 2000, although he does not quote from them in his study (Melton 2001: n. 1). The European team conducted its study of RFPs in East Grinstead (at Scientology's St. Hill facility) and Copenhagen between November 2000 and November 2001, interviewing twenty-four people and providing summaries of the interviews (Pentikainen, Redhardt and York 2002). Two of the European researchers-Pentikainen and York-are well known scholars, but I was unable to find any information on Redhardt other than the fact that he was on the program to deliver a paper at a Unification Church sponsored conference entitled "The Founders and Shapers of the World's Religions" in late November 1997. The European study cites Melton's paper, as well as an early version of my RPF work.

 When discussing both the Sea Organization and the RPF, the European study and Melton's study sound very similar in tone. They attempt to portray the Sea Organization in monastic contexts, at the same time failing to cite primary documents produced by Scientology itself that might cast it in a different, indeed a secular, light. Furthermore, both studies fail to mention the age at which youth can become full Sea Organization members (which in the early 1990s was fourteen if not younger), yetMeltonshould have known about this young age because he was quoted in a newspaper article in which a former Sea Org member talked about her life as a fourteen-year-old in the organization (Lattin 2001). Moreover, both studies neglect to mention the failure of the Sea Organization to have old-age pension systems or retirement homes for elderly or infirm members (which, by the way, respectable monastic institutions have). Sea Organization salaries never get specified, since they seem to be $50.00 a week but quite often are far less (Kent and Hall 2000: 53 n.8; Malka 2002). The exact nature of medical care for Sea Organization members was not clarified (and it certainly must vary from country to country), which is an important issue within an organization whose founder had bizarre and potentially dangerous ideas about the causes and cures of some illnesses (Circuit Court of the Sixth Judicial Circuit 2000). Neither study questions the legitimacy of the RPF's existence on ethical, legal, or human rights grounds. Moreover, both of them provide reasons for people entering the RPF program that reputedly emphasize their personal or role-performance failures or shortcomings rather than because of the unwieldy policies and questionable products of the group itself (Melton 2001: 13; Pentikainen, Redhardt and York 2002: 11). 

 Quite seriously, both sets of authors fail to inform readers that Scientology attempts to require people who want to drop out of the RPF (and who do not appear to be major threats to the organization) to do so only by "routing out." At least in the late 1970s, this process allegedly involved Scientologists culling auditing files (called pc or preclear folders) for damning personal information that they subsequently put into affidavits and had the exiting people sign (Rosenblum n.d.: 7). Persons leaving the RPF also were hit with what the organization calls a "freeloader debt" (often running into tens of thousands of dollars) for all of the free courses they had taken while active Sea Organization members (Hubbard 1976a: 225). Recently the probable impact of this debt on one former Sea Org member became tragically obvious when Eric Rubio, A Frechman living in Denmark, ran out of money and died of starvation even though for approximately seven years he had been paying back his freeloader's bill to Scientology (Malka 2002). These omissions from studies on the Sea Organization and the RPF are serious, since their absence makes it easier to maintain these abusive organizations as religious, benign, and voluntary.

 Additional problems exist around the European study in the context of research ethics. Obviously the researchers went through Scientology officials to gain access to RPF members, and the researchers subsequently referred to them only by their first names in the text. The ethical problem, however, should be obvious: the researchers were completely unable to provide anonymity to their subjects from the organization to which they belonged. Negative or critical comments would have propelled these RPF members back into the 'rehabilitative' stages of the program, conceivably costing them additional months if not years. Perhaps it is no wonder that no one told the researchers much of anything short of praise for the program. Moreover, as researchers, they missed a golden opportunity to gain new perspectives on the RPF when they apparently made no effort to track down and re-interview two persons whom they had interviewed earlier but who subsequently left the RPF program (Pentikainen, Redhardt and York 2002: 2). Also as researchers, they committed an ethical breach by publishing the full name of a person with whom one of their informants allegedly had "preliminary sexual contact" (Pentikainen, Redhardt and York 2002).

 6) Goodman's Failure to Protect Scientology's Children

 Clearly one area that needed an overhaul involved the extent to which RPFers' family contact prohibitions likely harmed (especially) children. Another was the likelihood that teens and children actually had been in the RPF itself. On these questions Goodman herself has direct knowledge, and her failure to act upon that knowledge is disturbing. Evidence is definite that she knows that they are (or at least were) in the RPF, yet she continues to defend the RPF program. I base my conclusion about her knowledge on evidence that appears in my RPF booklet published by the Hamburg government, in which I included a section entitled, "Children and Teens in the RPF." In a subsection in which I discussed "Television and Newspaper Accounts of Teenagers on the RPF," I presented the following information, never knowing how important it would be in a future debate:

Additional evidence that a Children's RPF operated in or near Los Angeles appeared in an unlikely source--an August, 1989 news broadcast from television station KOTO in Oklahoma City, Oklahoma. The news broadcast (of which I have a video copy) was the first in a series on Scientology's Narconon program--a reputed drug rehabilitation program that had begun to operate on an Indian reservation near Newkirk, Oklahoma. (Apparently the series ran in August 1989, but the television station was unable to provide me with an exact date. The announcer refers to events, however, that led me to conclude that it ran on August 21.) In one segment, reporter Larry Blunt was on the sidewalk presumably near the main Scientology complex in Los Angeles, having just completed an interview with Scientology spokesperson Linda [sic: Leisa] Goodman. The camera moved around to a scene unfolding across the street and some distance away, and Blunt offered the following commentary about what was captured on film:

Shortly after that exchange [with Goodman], a Scientology bus loaded with young people dressed in black pulled up. They jogged into the Scientology complex. A recent defector of [sic: from] Scientology told me they were from the Church's Rehabilitation Project Force. They were found to be a problem, and need an attitude adjustment (KOTO 1989).

This film segment is over in a matter of seconds, but viewers are able to count at least thirteen teens (two or more who appear to be females), all wearing dark suits (with short sleeves and short pants). Of course, the dark uniforms and the jogging requirement are standard for people assigned to the RPF. While the Scientology organization may insist that adults in the RPF program are there willingly, it is difficult to imagine this justification (or excuse) applying to teens whose presumed ages would suggest that they should be under the care of parents or guardians (Kent 2000: 43).

I have to assume that Goodman either saw for herself what the camera filmed or watched the final news broadcast as (or after) it aired. Not surprisingly, neither Goodman nor Melton, nor the three European scholars discuss the important human rights issue of children and teens in the RPF, and certainly Goodman has some knowledge about it.

7) Character Aspersions

 Because I persist in raising human rights issues about the RPF program, I am (according to Goodman) a "propagandist advocating a cause. " In doing so I am failing to maintain expectations placed upon professors to be "thorough, fair, honest, and free from preconceptions offered as conclusions." Alas, on the issue of (alleged) discrimination against German Scientologists, I show "wilful ignorance" (Goodman 2001: 2). She cites two academics who have criticized either me or my work (Goodman 2001: 2, 3), and these critics become part of her attempt to represent my scholarship as "an effort to coat human rights violations [against Scientologists] with a veneer of legitimacy" (Goodman 2001: 4).

 Omitted from her (small) list of my detractors is the respected journalist, Douglas Frantz, who (for a brief period) also made disparaging comments about me in a speech that he delivered to other investigative journalists and that were posted on the website of a reputable journalistic institution. Looking at these disparaging comments will help place Goodman's current statements into an appropriate context.

 To an audience of investigative reporters attending a May 15, 1999 conference at the Nieman Foundation for Journalism at Harvard University, Frantz gave advice to reporters investigating nonprofit organizations. He had obtained international recognition for his New York Times articles on Scientology, one of which included a quote by me (Frantz 1997b: A14). Based upon what happened to him after the article appeared, Frantz's third suggestion to his audience was, "Don't Give Advice to Sources." In illustrating why this was so, he cited an incident that allegedly involved me.

 After his second major Scientology story appeared-which was about the death of a Florida woman in Scientology's care and in which he quoted me--a woman called him with "very interesting" financial information about her husband's dealing with the organization. When finished with her story, she asked Frantz:

'Who can I go to find out more about this church?' I gave her a piece of advice, and I wish now I hadn't. It seems a little too pure perhaps, but I wish I hadn't, because I told her, 'Talk to this guy, Stephen Kent, at the University of Alberta.'

I quoted him in the story, she could have figured it out on her own, but what happened was she called Kent-and I found this out later as I sat in the office of Scientology out in Los Angeles-she called Kent, Kent put her in touch with a deprogrammer named Rick Ross down in Arizona, and Rick Ross told her how she could infiltrate the church and go in and find out about the church personally and then she was to come back out and tell this information to Rick Ross.

So, lo and behold, she went into the church and she lasted about three days, and they're going through their tests and stuff and she confessed to her Scientology handler that, "This is how I got her[e]," and so it came right back to me, and what it did was make Scientology question my motives because it looked like to them like I had taken a strong side against them, and I'd made a mistake, and I told them, I told them exactly what happened, that I had made a mistake because I violated my own rule, and it's a rule I think about which you cannot be too pure (Frantz 1999).

I do not know how many people were in the audience, but after Frantz's talk appeared on the Nieman Foundation's website, someone alerted me to it.

 In retrospect, Frantz's account taught me a great deal about Scientology, since the central facts in that account were false. Apparently, Scientology's brazen and bold presentation of them as being true was so clever that Frantz never considered that he was becoming an unwitting accomplice in a character assassination operation against me. The entire story about my alleged advice to a woman who supposedly called me upon Frantz's instruction was manufactured. It never happened. No one called me upon recommendation from Frantz, which means that everything else in the story was fabricated. I did not recommend someone to Rick Ross; Ross did not advise someone to go into Scientology surreptitiously in order to gather information; and Scientology did not catch such a person after three days. Consequently, I challenged both Frantz and the Nieman Foundation to either prove the allegation about me or remove it from the Foundation's website. In response, the Foundation removed the description of this alleged incident and Frantz issued me an apology. Succinctly written, his notarized apology stated:

At the 1999 Watchdog Journalism Conference for the Nieman Foundation for Journalism at Harvard University, I made comments about Dr. Stephen A. Kent of the University of Alberta that I thought were accurate.

Subsequently, I acquired information that led me to conclude that these comments concerning Dr. Kent were not accurate. Consequently, I withdraw them, and I apologize to Dr. Kent for any difficulties that they have caused him" (Frantz 2000).

Legally, I then considered the matter closed. Educationally, I learned a great deal about the organization-Scientology-that perpetrated the deception.

 Using an older term from Scientology itself, the character assassination action against me was a "fair game" action. Melton alluded to the "fair game" policy in actions against author Paulette Cooper in the 1970s, but incorrectly stated that the covert plan against her was "never implemented" (Melton 2001: n. 26). In fact, Scientology operatives most certainly implemented the covert plan, code named "Operation Freakout" against her, and it almost destroyed her financially and emotionally. As reported in the New York Times, in December, 1972 someone mailed two bomb threats to the Church of Scientology on Cooper's stationary that contained her fingerprints. (The most likely explanation was that a Scientology operative, posing as a person collecting donations for a liberal cause, gained access to her apartment and stole stationary that was sitting on a table.) The Federal Bureau of Investigation (FBI) questioned Cooper, and a grand jury eventually indicted her on two counts of sending bomb threats. Meanwhile, an anonymous, character-assassination letter against her circulated in her apartment building. Only after passing a sodium pentathol test did federal authorities drop the charges. After the FBI raided Scientology offices in 1977, it recovered documents about "Operation Freakout" which revealed that operatives were planning (other) bomb threat frame-ups against her, with the intent of getting Cooper "'incarcerated in a mental institution or in jail'" (New York Times 1979). About, therefore, Scientology's harassment of Paulette Cooper, Meltongot his facts wrong when he stated that Scientology had not implemented a plan to get her incarcerated. 

 Melton got more things wrong about Scientology's dirty tricks and character assassination attempts by implying that they ended with the abolition of the Guardian Office in the early 1980s. My own experience, and the experience of many others, indicates that these operations against perceived "enemies" continue, as I even have discussed in a recent legal declaration that I wrote (Kent 2001b: para. 5-32). Indeed, Scientology has picketed against me on my campus; it has equated me with a holocaust denier and distributed this false allegation in newspapers in two Canadian cities (because of my work on the Scientology debate in Germany); and it has written several letters of protest against me to my University's administration (see Rusnell 1998). Most recently, in June 2002, a lawyer (Elliot Abelson) representing the Church of Scientology International served me with a letter charging that I had: 

engaged in various activities in conjunction with Gerald Armstrong which fall within the general category of anti-Scientology public statements. These have included trips to Europe where you and Mr. Armstrong have appeared together at various public gatherings, all with the same anti-religious agenda (Abelson 2002).

Based upon these assertions, the letter then charged that I was "'acting in concert'" with Armstrong to break a California court order that is supposed to silence his ability to criticize Scientology. Although the letter gave no specifics about my alleged actions with Armstrong, it probably was in reaction to my having written about Armstrong's case in my previous article in this journal (Kent 2001c). In it I mentioned Armstrong's talks, meetings, and media interviews in Germany, and I suspect that Abelson and/or the Church of Scientology International assumed that I was there with him. I was not, nor have I ever been in Europe with Armstrong. Abelson's letter, therefore, simply is an attempt to link me with Armstrong with the possible long-term goal of getting me charged as a conspirator helping him break his silencing agreement.

 I am not the only sociologist of religion to experience Scientology's "fair game" tactics. The late Roy Wallis, who published an important book on the organization in the mid-1970s (Wallis 1976), also wrote about what happened to him while he was conducting his research (Wallis 1973). A Scientology spy tried to get Wallis to let him stay at his house; he received a somewhat threatening phone call from him; and forged letters appeared both about him and supposedly by him that attempted to get him in trouble with colleagues and his university. As Wallis concluded:

the implication is strong that, whether with or without the connivance of the leadership of the Scientology movement, I was the subject of a concerted attempt at harassment designed to 'frighten me off' Scientology, to undermine my credibility as a commentator on their activities, or to keep me so busy handling these matters that I had little time for research (Wallis 1973: 547).

When I look at what has happened to me, I realize that little if anything has changed in three decades concerning Scientology's 'fair game' activities.

8) Did Not Say It; Did Not Do It; Not Guilty of It

 Perhaps the experience of reading Douglas Frantz's comments about something that never occurred should have prepared me for what was to come in response to my on-going Scientology research, but I still admit to being startled when I get criticized for things that simply are not true. These unwarranted criticisms are attempts to discredit me in a manner that will reflect upon my scholarship, but they say considerably more about those who formulate them. For example,Melton insisted:

In spite of Steven [sic] Kent's study of Scientology over the last decade, he continually makes fundamental errors in reporting on Scientology's beliefs and practices. For example, his lack of knowledge of Scientology is manifest in his discussion of the False Purpose Rundown. It is one set of what in Scientology are called 'security checks' or 'sec checks.' Kent asserts that 'sec checks' are not covered by the same rules of confidentiality as auditing. In fact, security checks, of which the 'False Purpose Rundown' is an example, are one form of auditing, the kind used to deal with overts and withholds, and are covered by all the confidentiality rules governing auditing (Melton 2001: n. 67).

Melton provided no citation to my reputedly mistaken discussion because, at the time that he wrote his analysis, I had never discussed the auditing technique called 'The False Purpose Rundown.' I was precise when I discussed sec checks (not false purpose rundowns) that took place against people who were in and around the RPF, and I even quoted an excerpt from a technical bulletin (entitled "The Only Valid Security Check") that Hubbard wrote in 1961 (and that the organization reprinted in 1976) stating that the Scientology staff member administering it did not guarantee the confidentiality of the answers (Kent 2000: 38-40, 54). 

 While both the False Purpose Rundown and sec checks ask intrusive questions, the former focuses primarily on issues related to auditing mistakes-mistakes of process. Sec checks, in contrast, pry into very personal issues, ostensibly to see if any of these issues might make the person an organizational threat. According to Hubbard's own instructions, staff members about to administer sec checks to other members are to say to them:

'We are about to begin a Security Check. We are not moralists. We are able to change people. We are not here to condemn them. While we cannot guarantee you that matters revealed in this check will be held forever secret, we can promise you faithfully that no part of it nor any answer you make here will be given to the police or state' (Hubbard 1976b: 276).

The document is clear: sec check material is not confidential. No guarantee exists that the answers "will be held forever secret" like auditing files are supposed to be (or so the organization claims).

 Furthermore, after Melton's paper already was on the Internet, another article of mine finally appeared in print (in early August 2001, despite the article's December 1999 publishing date) in which I specifically mentioned the False Purpose Rundown. In the context of discussing Scientology's attacks on psychiatry and Christianity, I stated:

In a 1984 Hubbard Communications Office Bulletin designed to repair problems associated with aspects of auditing, auditors were required to ask preclears a series of 109 questions, including question 102: "IN THIS LIFETIME, HAVE YOU BEEN IMPLANTED BY A PSYCHIATRIST OR PRIEST?" (Kent 1999a: 118 n. 7).

At least, therefore, on the topic of security checks, I am not the one making fundamental errors.

 It would be tedious for me to respond to all of Goodman's and Melton's criticisms, so I only will address the most important ones. While any scholarship necessarily is subject to adjustment, corrections, and dispute, I suggest that readers view Goodman's criticisms of me and my work in the context of 'fair game actions.' For example, she asserts that I have never been in any Scientology churches, which assumes that the group actually has churches to attend. The group does not; some organizations have chapels that they use for occasional services. As I indicated, however, in a witness statement in early 1998, I have attended various Scientology events, and met with Scientologists in their respective offices in Montreal, Toronto, and Los Angeles. These events included a Sea Org recruitment meeting in Edmonton, and an exclusive Scientology party in Toronto (Kent 1998: 1-2). I even photographed the president of the Church of Scientology International, Heber Jentzsch, in his impressive office in Los Angeles. My concerns, therefore, about likely human rights violations in relation to some of Scientology's practices have not been alleviated by my professional contact with Scientology practitioners.

 Nor can Goodman dismiss my analysis of the RPF by asserting that I have never seen it in action. I have, but under circumstances that she would not expect. Thanks to German film-makers Peter Reichert and Ina Brockmann, I have footage from Clearwater, Florida that shows the RPF in action in two separate Scientology work-settings. They shot this footage from land that was not Scientology's, so they broke no trespassing laws in acquiring it. Important about this footage is that the organization did not know its members were being observed, so the situations and behaviours were not altered to present RPF life in any manner whatsoever.

 While I certainly would welcome an opportunity to visit an RPF in operation, serious ethical issues would need addressing first. For example, it would be impossible to guarantee the anonymity and confidentiality of RPF inmates (as standard professional ethics policies require), which could have dire consequences for them. Any less-than-positive statements about the program that inmates might make could have unacceptable consequences for them. For these reasons alone (and there are others [Kent 2001a: 406-407]), the very conditions under which Scientology operates the RPF makes interviewing current inmates ethically impossible.

9) Correcting the Facts 

 Nothing is more tedious than reading authors quarrel over (often tendencious) positions. Small points to readers become inflated positions to disputants, and amidst the squabbles, big issues get neglected. Some very big issues exist in the international debate about Scientology, yet I cannot let many of the smaller points stand uncorrected. Quickly, I will address some of them.

9.1) Scientology and the Demise of the Cult Awareness Network

 Goodman spends considerable time discussing the civil court case that destroyed the old Cult Awareness Network (CAN), and, indeed, it was a big win for her organization. Elsewhere I and others have detailed Scientology's orchestration of that suit, including the financially debilitating legal assault that Scientology launched against CAN prior to the final civil trial (CBS 1997; Goodstein 1996; Kent and Krebs 1998b: 40-42). The most important evidence that I and a co-author discovered about that case was that the courts had been incorrect in assuming that a connection existed between the person (Shirley Landa) who provided a deprogrammer's name to a concerned relative in the Seattle, Washington area and the CAN office near Chicago (Kent and Krebs 1998a: 48-49 n. 49). Without that connection, CAN should never have been included as a defendant in the civil suit, yet the fact that it was, and that the ruling bankrupted it, is a testament to Scientology's skillfully relentless litigation strategy.

 Goodman dismissed my attribution of the demise of CAN to Scientology, (Goodman 2001: 2), but Scientology itself made sure that its members knew that the lead counsel in the prosecution was one of their own. In a 1995 article in International Scientology News, the Church of Scientology International included an article about the civil verdict against its foe. That article informed readers, "[t]he victim, Jason Scott, was ably represented in the trial by Kendrick Moxon, who is a Scientologist" (Church of Scientology International [CSI] 1995). Not only was Moxon a Scientologist, but also he applied Scientology doctrines in bringing down CAN. As an issue of the Impact-the magazine of the International Association of Scientologists--revealed:

'A civil case was filed by the victim against [Rick] Ross and the Cult Awareness Network. This time he had an attorney who knew what he was doing and understood PTS/SP tech! The attorney was a Scientologist and OT [Operating Thetan] Rick Moxon' (Kurt Weiland, quoted in International Association of Scientologists Administrations 1995: 12).

"PTS/SP tech" refers to Hubbard's policies of attacking presumed enemies (called suppressive persons or 'SPs') and the people who associate with them (called potential trouble sources or 'PTSs'). CAN, of course, was the major American SP group, and Scientology had carried out operations against the organization for years before Moxon helped litigate its bankruptcy.

9.2) Scientology's Own Criminality

 One final word about CAN: Goodman's portrayal of it as having been a criminal organization simply is false. Neither it nor its director, Cynthia Kisser, had any criminal convictions against them. A Canadian branch, however, of Goodman's organization, Scientology, does have a criminal conviction-two breach of trust convictions against the Church of Scientology of Toronto in 1992 and upheld in appeal in 1997 (Court of Appeal for Ontario 1997: 1, 143). These convictions stemmed from an extensive spy operation that Scientology ran in (often successful) attempts to steal Scientology-related documents from various Ontario government and law enforcement agencies between 1974 and 1976. These agencies included the Ontario Provincial Police, the Ministry of the Attorney General, and the Metropolitan Toronto Police (Court of Appeal for Ontario 1997: 11). "Scientologists secured employment with government agencies perceived to be enemies of the Church, and signed oaths of secrecy as public officials," and then removed documents that related to the Scientology organization (Court of Appeal for Ontario 1997: 1). This policy of planting Scientology agents in key organizations developed after a Scientology official decided that its previous policy of burglary was too risky (Court of Appeal for Ontario 1997: 11-12). Worth reading are the appellate judge's comments when he ruled against Scientology of Toronto's attempt to appeal the conviction and sentence of a $250,000.00 (CDN) fine:

This conduct represented a deliberate attempt to undermine the effectiveness of the law enforcement agencies. The acts struck at the integrity of the public service. This was not simply an intelligence-gathering exercise. The appellant had planted its agents in these agencies so that they would be able to anticipate and counter the efforts of these agencies to enforce the law (Court of Appeal for Ontario 1997: 137).

As has always been the case when trying to explain the actions of the Guardian Office, the Scientology organization refused to accept responsibility for these illegal actions: 

The appellant at no time admitted responsibility for these offences or expressed remorse for its involvement.... [T]he evidence was clear that the appellant stopped this kind of activity because the risk of discovery was putting the appellant and the Church of Scientology in jeopardy. In the years leading up to the commission of these offenses, the Church had tried various illegal means in a misguided effort to protect itself from those agencies, organizations and individuals that it perceived to be its enemies. When the risk of detection became too great, a particular technique would be abandoned in favour of some better or different method. The various actions such as the 'amends programme', which forced the individuals to accept personal responsibility, were mechanisms by which the appellant distanced itself from the acts committed on its behalf (Court of Appeal for Ontario 1997: 139).

 In sum, Goodman falsely accused CAN of criminality when an affiliate of her own organization actually has a serious criminal record. In this instance, even when opponents are not criminals, a Scientology spokesperson will label them as such, despite the fact that the 'criminal' moniker aptly fits a Scientology organization.

10) Goodman's Portrayal of Critics

 The same degrading tone that she used to incorrectly portray CAN also appears in her comments about the German critic and Hamburg government official, Ursula Caberta. Her statement for example, that Caberta-whom she labels a human rights abuser-- has not found "anything wrong with Scientologists and their Church" (Goodman 2001: 2)-could only have been made by someone who is not paying attention. Caberta has a litany of issues with Scientology-alleged financial coercion of members; the assignment of Germans to the RPF; often deplorable working and living conditions in the Sea Organization; possible business fraud; highly questionable drug and radiation treatments; building code violations; alleged extortion in the housing market; etc. Most recently, for example, Caberta assisted a twenty-three-year-old woman, Vivien Krogmann Lutz, in her successful lawsuit against her Scientologist mother and step-father for putting her in the Sea Org at Saint Hill when she was thirteen. The hard labour that Sea Org officials forced her to endure caused her permanent orthopedic injury, and her parents agreed to pay her 35,000 Euros after the trial had run only for three hours (Gormez, 2002).

<http://www.whyaretheydead.net/childabuse/vivien/?FACTNet> (http://whyaretheydead.net/childabuse/vivien/?FACTNet On another issue, Goodman insisted that the Nigerian government has filed a criminal complaint against millionaire critic Robert Minton (Goodman 2001: 2), when in fact false allegations very similar to these landed Scientologists a fine in a Berlin libel case that Minton won on March 27, 2001-shortly before Goodman published her response to me (Berlin State Court 2001). (Minton's current relationship with Scientology and its critics has become sufficiently complex and convoluted that I cannot hope to unravel it in this response.) These character-attacks shift attention away from crucial issues by attempting to depict opponents as disreputable. As has happened in this exchange, however, frequently Scientology is guilty of the same disreputable behaviour that it blames on others.

11) Scientology's Secret Agreement with the Internal Revenue Service

 Again, the crucial issue that we always must keep in focus is the probability that Scientology has committed sufficiently serious human rights abuses that various European countries such as Belgium, France, and Germany are justified in their opposition to it. Since Scientology has met far less resistance in the United States, Goodman wishes to portray her organization's successes in that country in a favourable light. Central to this portrayal was the Internal Revenue Service's agreement to give Scientology and its many affiliates charitable status, and Goodman makes it sound like that decision was the most rigourous ever undertaken by that agency. Critics point out, however, that the procedures that the agency utilized were most unusual, with the negotiating agents being instructed not to follow standard procedures when coming to their conclusions about the organization's status. Consequently, the resulting secret agreement between Scientology and the IRS probably is illegal.

 I will not undertake a complex history of American Scientology litigation in the context of the group's religious claims, but suffice it to say that as Scientologists and IRS officials were hammering out an agreement behind closed doors, a United States Claims Court upheld a lower court decision that a central Scientology organization, the Church of Spiritual Technology, "was founded for the primary purpose of gaining tax-exempt status to serve the financial goals of other, non-exempt entities...." (United States Claims Court 1992: 1). Despite this ruling, the IRS granted Scientology tax-exempt status the next year, and a New York Times investigation about the decision "found that the exemption followed a series of unusual IRS actions that came after an extraordinary campaign orchestrated by Scientology against the agency and people who work there" (Frantz 1997a: 1). Indeed, the "special committee" that the IRS commissioner established at the time was "outside normal agency procedures. When the committee determined that all Scientology entities should be exempt from taxes, IRS tax analysts were ordered to ignore the substantive issues in reviewing the decision . . ." (Frantz 1997a: 30). Many questions, therefore, remain about the procedures that the IRS used in determining Scientology's tax-exemption, and Goodman's comments do nothing to answer them.

 These procedural questions are so significant that judges in the Ninth Circuit United States Court of Appeals have addressed them. The judges did so in a ruling for a case in which the plaintiffs (Michael and Marla Sklar) tried (unsuccessfully) to use Scientology's charitable status as a precedent for receiving charitable deductions for their children's tuition for attending a religious school. The appeals court specifically discussed the IRS's refusal to make public the conditions of the Scientology agreement (even after the Wall Street Journal published it), and then turned its attention to the constitutionality of the agreement itself. A succinct summary of the case appeared in the Los Angeles Times:

The judges said the Sklars were not entitled to a refund under either IRS regulations or applicable Supreme Court precedents.

The leading precedent, the judges said, is a 1989 high [i.e. Supreme] court decision holding that payments Scientologists made for 'auditing' did not constitute charitable contributions.

 That decision, Hernandez vs. Commissioner, was based on a section of the Internal Revenue Code that states that quid pro quo donations, for which a taxpayer receives something in return-are not deductible. The Hernandez decision held that the section applies to religious quid pro donations.

In Tuesday's decision, the appellate court criticized the IRS for refusing to disclose the terms of a 1993 settlement with the Church of Scientology. That agreement, among other things, permits Scientologists to get deductions in conflict with the 1989 Supreme Court decisions, according to the 9^th Circuit (Weinstein 2002).

The appeals court decision itself contains some remarkable passages.

 When considering the IRS's secrecy regarding the final Scientology agreement, the judges wrote:

Here, there is strong public interest in the disclosure of the contents of the IRS's agreement with the Church of Scientology, especially as the agreement establishes a new policy governing charitable contributions to a particular religious organization which, while the pertinent statute may be unclear, clearly contravenes a prior Supreme Court holding.

Therefore, we reject the argument that the closing agreement made with the Church of Scientology, or at least the portion establishing rules or policies that are applicable to Scientology members generally, is not subject to public disclosure. The IRS is simply not free to enter into closing agreements with religious or other tax-exempt organizations governing the deductions that will be available to their members and to keep such provisions secret from the courts, the Congress, and the public (United States Court of Appeals for the Ninth Circuit 2002: 5).

In other words, this court rejected the IRS's reasons for keeping secret the contents of its agreement with Scientology, which is the same conclusion that a circuit court also had reached (United States Court of Appeals for the Ninth Circuit 2002: 4).

 Equally consequential was this court's comments about the inappropriate motivation that propelled the IRS to make the secret deal. That motivation, the court concluded, was in reaction to Scientology's litigiousness. In a phrase, the IRS was motivated to enter into the agreement not because of any legal compulsion to correct an alleged wrong against Scientology, but because of the time and money it was expending in litigation with the organization. In the words of the court:

Although it appears to be true that the IRS has engaged in this particular preference in the interest of settling a long and litigious tax dispute with the Church of Scientology, and as compelling as this interest might otherwise be, it does not rise to the level that would pass strict scrutiny. The benefits of settling a controversy with one religious organization can hardly outweigh the costs of engaging in a religious preference (United States Court of Appeals for the Ninth Circuit 2002: 5).

In short, the IRS made a mistake in granting Scientology charitable status primarily as a means of ending lengthy and costly litigation.

 Not only was the IRS agreement with Scientology unwise, but also it apparently was unconstitutional. Once again, on this point the appeals court judges were clear:

Because the facial preference for the Church of Scientology embodied in the IRS's policy regarding its members cannot be justified by a compelling governmental interest, we would, if required to decide the case on the ground urged by the Sklars, first determine that the IRS policy constitutes an unconstitutional denominational preference . . . (United States Court of Appeals for the Ninth Circuit 2002: 6).

One of the concurring circuit judges who heard the Sklar case, Judge Barry G. Silverman, apparently was so displeased with the IRS's agreement with Scientology that he "invited people who are troubled by the IRS settlement with Scientology to file a lawsuit to unravel the deal" (Weinstein 2002):

If the IRS does, in fact, give preferential treatment to members of the Church of Scientology-allowing them a special right to claim deductions that are contrary to law and rightly disallowed to everybody else-then the proper course of action is a lawsuit to put a stop to the policy (United States Court of Appeals for the Ninth Circuit 2002: 9).

The article about the Sklar case in the Los Angeles Times called this advice by the judge "a highly unusual move" (Weinstein 2002). Leisa Goodman, therefore, is fooling no one by claiming that her organization received charitable tax status in the United States because of the compelling and legally justified nature of its case. Probably its litigiousness simply wore down the IRS (see Kumar 1997), whose officials finally capitulated to the pressure and became parties to an apparently unconstitutional agreement that ignored a Supreme Court decision.

12)  Proof, Documentation, and Evidence 

 Finally, I must object to Goodman's assertion that "Kent, unlike the courts, does not require his sources to document what they say . . ." (Goodman 2001: 2). This assertion simply is incorrect. I used at least two dozen Scientology documents in my RPF analysis, in addition to fourteen documents from Susanne Schernekau/Elleby that she removed from the RPF facility in which she had laboured. I also cited two court cases in which judges mentioned the RPF-one American, the other British-both of which were highly critical of Scientology's actions. Most detailed about the RPF was an American case that involved a favourable decision to former Scientologist Lawrence Wollersheim, and a short section of it is worth reproducing:

There also was evidence Wollersheim accepted some of his auditing under threat of physical coercion. In 1974, despite his repeated objections, Wollersheim was induced to participate in auditing aboard a ship Scientology maintained as part of its Rehabilitation Project Force. The Church obtained Wollersheim's attendance by using a technique dubbed 'bait and badger.' As the name suggests, this tactic deployed any number of Church members against a recalcitrant member who was resisting a Church order. They would alternately promise the 'bait' of some reward and 'badger' him with verbal scare tactics. In the instant case, five Scientologists 'baited and badgered' Wollersheim continuously for three weeks before he finally gave in and agreed to attend the Rehabilitation Project Force.

But these verbal threats and psychological pressure tactics were only the beginning of Wollersheim's ordeal. While on the ship, Wollersheim was forced to undergo a strenuous regime which began around 6:00 A.M. and continued until 1:00 the next morning. The regime included mornings of menial and repetitive cleaning of the ship followed by an afternoon of study or co-auditing. The evenings were spent working and attending meetings or conferences. Wollersheim and others were forced to sleep in the ship's hole. A total of thirty people were stacked nine high in this hole without proper ventilation. During his six weeks under these conditions, Wollersheim lost 15 pounds.

 Ultimately, Wollersheim felt he could bear the regime no longer. He attempted to escape from the ship because as he testified later, 'I was dying and losing my mind.' But his escape effort was discovered. Several Scientology members seized Wollersheim and held him captive. They released him only when he agreed to remain and continue with the auditing and other 'religious practices' taking place on the vessel (California Court of Appeal 1989: 9274).

My interpretation of the RPF is entirely consistent with this appellate court's brief summary of its contents and harsh conditions. Indeed, in a conclusion that supports directly my description of the RPF, the appellate court stated, "this episode demonstrated the Church was willing to physically coerce Wollersheim into continuing his auditing" (California Court of Appeal 1989: 9274).

 Alas, because of Scientology's behaviour toward Wollersheim regarding this case, Goodman's plea to the propriety of using court evidence is disingenuous. In 1986, Wollersheim won his first action against Scientology for its egregious behaviour toward him. While one subsequent trial lowered the amount of money that Scientology owed Wollersheim, the organization continued its refusal to pay up, finally giving him nearly $8.7 million in May 2002 as it faced dire legal and financial consequences for its continued refusal (Los Angeles Times 2002). In response, therefore, to Goodman's assertion that I, unlike the courts, do not support my claims with evidence, in the case of the RPF it seems that Goodman's organization does not accept court decisions when they reveal dark sides of her organization.

 A crucial aspect of Goodman's portrayal of American Scientology necessarily involves attempts to discredit my research on the RPF, which operates in the United States and elsewhere. Goodman and others rely upon two arguments. First, according to American scholar Frank Flinn, the RPF is similar to "religious practices around the world" and hence is legitimate. Second, Lorne Dawson criticizes my RPF study because I used the accounts of former members (Goodman 2001: 2). Well, to some extent Flinn is correct: the prison-like RPF has similarities to some programs in various religions, but those programs themselves are abusive! For example, The Family (formerly known as the Children of God), ran training camps for their teenagers in the 1980s and early 1990s, and they contained additionally punitive programs called "Victor Camps" that involved incarceration and physical maltreatment, in combination with "intense ideological training consisting of indoctrination classes, social isolation, and forced confessions, often combined with extremely hard physical labor and social humiliation" (Kent and Hall 2000: 57-58). Similarly, the American drug-treatment-program-turned-religion, Synanon, imposed a boot camp program on both old and new members that bares resemblance to Scientology's RPF (Gerstel 1982: 160-161; see Kent 2001a: 366). Even more extreme was the brainwashing program inflicted by Colonia Dignitad officials onto members in Chile, which apparently surpassed even the RPF for its harshness (if not its brutality [Coad 1991; Kent 2001a: 367]). If, therefore, the RPF resembles programs in other, more established religions, then those programs likely are abusing the rights of people in them.

 On the issue of former members, suffice it to say that it is unbelievably bad methodology to exclude former members' accounts merely on the ideological assertion that they must be biased. Social scientists must attempt to verify information provided by all of their sources, regardless of their relationship with an organization about which they are informing. Former members often turn out to be extraordinary informants, simply because they know their topic 'from the inside'-having lived it-and they are no longer under a group's immediate control. I suspect that Goodman and other members of ideological organizations have worked so diligently to destroy the credibility of former members because they have seen the high quality of much of the information that they have provided to the media, the courts, and those of us in academia who were willing to listen to them.

13) Scientology's Problems in Germany

 Having addressed Goodman's accusations about the quality of my documentation, I note that Goodman accused me of citing a 1995 German labour court opinion that other German courts (supposedly) have ignored. I first cited this case in an article published in the prestigious journal, Religion (Kent 1999b: 158 n. 163), and then (in the Marburg Journal of Religion article) excerpted a passage from a letter written by the German Ambassador to the United States who also quoted from it (Kent 2001c: 3). In response, Goodman asserted, "[w]hile Kent may like to quote this opinion, German courts ignore it" (Goodman 2001: 5). Well, no they do not. A simple Internet search shows at least three legal decisions involving Scientology (all of which the organization lost) that include citations to that case.^[1] Goodman, however, may have difficulty accessing them, since these cases appear on the web site of a German critic of Scientology named Tilman Hausherr, and his name is one of many that Scientology censor or web-filter software is designed to block (Heldal-Lund, 2003; see Brown, 1998). In short, Goodman may not be able to access his site.

 Many German scholars on Scientology have detailed understanding of their country's legal system, and some of them are writing about the state of that organization in their country. One such scholar, Brigette Schoen, provides what seems to be a reliable analysis of Scientology's legal situation in Germany, so it is worth mentioning her findings. First, in a recent article that was critical of many current interpretations of the Scientology situation in Germany, Schoen pointed out that, "[a]part from Scientology, no new religion has been denied its religious character by any German court. Even in Scientology's case, rulings have been mixed and the issue is far from being settled" (Schoen, 2002: 103). All of us, therefore, will benefit when an article appears (probably next year) by an Australian scholar who summarizes and analyses key German court cases involving the organization (Taylor, forthcoming).

 Second, Schoen provides a succinct analysis about how and why the German government placed the organization under surveillance. According to Schoen, by 1992 ministers of the interior had sufficient concerns about Scientology that they began to explore what legal options they had toward it. Several years later:

The decisive factor behind the decision to put Scientology under surveillance in 1997 was a legal opinion by an intelligence service task force, which had been ordered by the ministers of the interior's conference the year before. This rather dry report is based mainly on writings by Hubbard and Scientology, and examines whether these writings match the provisions of the federal law on the protection of the constitution . . . . The case in point, however, is not that statements such as granting civil rights and citizenship in the future to non-'aberrated' persons only would show that Hubbard intended Scientologists to discriminate against particular individuals and groups in an elitist manner that is incompatible with democracy. Discrimination by private parties against third parties does not endanger the constitutional order. What is taken to be anti-constitutional about the above statement is that is presupposes the abolition of the basic elements of the current constitutional order as well as the legal system and the universal validity of human rights. This matches with plans stated in internal papers of Scientology to implement Scientology's jurisdiction in society. In this manner, the report analyzes the potential political consequences should Scientology establish its ideal society (Schoen 2002: 107).

Scientology, therefore, has only itself to blame for the basic difficulties that it is experiencing in Germany. The writings of its founder have generated legitimate concerns about the compatibility of the organization within a society attempting to honour human rights and maintain an equitable legal system.

14) Conclusion

 After the disastrous apologetics that some academics produced during the early stages of the Aum Shinri Kyo investigation (Reader 2000), scholars should be especially sensitive about providing studies whose blind spots allow malfeasance to go unnoticed. Controversial groups use scholars for their own ideological ends, and Scientology is no exception. The goals of this ideological organization involve 'clearing the planet' of opposition and critical scrutiny. As long as critics focus on the organization's probable human rights abuses, government officials in various countries throughout the world will continue to raise difficult questions about the living and working conditions of Scientology's most dedicated, Sea Organization members.

 Let there be no doubt: Scientology acutely realizes the crucial role that academics can and do play in its globalized legitimation efforts. In a 1995 speech to the International Association of Scientologists, the Deputy Commanding Officer of the Office of Special Affairs, Kurt Weiland, presented to the audience a succinct statement about the role of scholars in assisting Scientology with its worldwide goals. As reported later in the International Association of Scientologists' magazine:

Mr. Weiland went on to explain that one of the actions needed to secure peace for Scientology with all governments in all countries of Earth was to obtain comprehensive studies and treatises on Scientology from the world's leading religious and sociological scholars.

Scholars from the United Kingdom, Finland, Russia, Japan, Norway, Holland, Poland, Belgium and elsewhere have been authoring their reviews which have been uniformly positive.

'The results and conclusions of these experts,' Mr. Weiland went on, "are beyond our expectations although I guess they shouldn't have been.

'The experts, as they learn more and more about Scientology are intrigued by our religion and its success. In fact five of the experts have decided to write a book about Scientology and one decided to get Book One [i.e., Dianetics: The Modern Science of Mental Health] auditing.'

 Mr. Weiland explained how these documents are now being translated so that they can be used in every country, providing an overwhelming presentation that is universal in its conclusion. The expertises are not only used in courts and tax agencies. They are being disseminated to government agencies and officials, universities and religious organizations. It is a massive project and has been funded entirely by the IAS (International Association of Scientologists Administrations 1995: 13).

While certainly not intended to be so, let this statement be a multi-leveled warning to scholars working on Scientology. 

 On the most obvious level, Weiland's statement indicates that this group will be using scholars' writings in intensely fought political and social battles. Scholars writing on Scientology may see their actions as objectively neutral, but the organization will attempt to utilize their academic products to further an ideological agenda that has disturbing implications for human rights. Moreover, amidst a growing mound of academic accolades, the voices of dissenters may get smothered. People whose only set of credentials come from years of inside involvement-who have seen and lived the issues about which the academics are writing-may find it increasingly difficult to tell what they know to people in power who need to hear it.

 On a deeper level, however, Weiland's identification of a scholarly evaluation of Scientology that is "an overwhelming presentation that is universal in its conclusion" bodes ill for those few of us whose knowledge of the organization and its policies leads to less-than-favourable conclusions about it. In essence, the organization will follow the policies against "suppressive persons" that its founder developed and try to silence us. Certainly I see Leisa Goodman's unscholarly attack on my scholarship in this light.

 I am concerned, moreover, about the implications of the Sea Organization/RPF studies produced by GordonMeltonand the European scholars. They are vague (almost to the point of silence) about how they came to undertake their research; how the Scientology organization fit into their research design; how much the studies cost; and whether Scientology itself assisted with any of the expenses. After the Aum Shinri Kyo debacle, scholars should have learned how important it is to provide readers and the public with as much information as we can about the practicalities of the studies themselves. Now this lesson is even more important, since Scientology has told its members how it is using our findings to further their cause. (Just for the record, I conducted this research with no additional funding and support beyond what my university provides its professors in the everyday conduct of their jobs.)

 Although I have raised serious issues about two studies of the contemporary Sea Org and the RPF, part of me nevertheless hopes that their relatively benign findings are correct. I do not want to see the abuses of earlier days imposed upon new generations of members. Yet the private legal system, the ridiculous pay, the undermining of familial (especially parental) relationships, the years spent 'rehabilitating' in a highly restrictive and demanding environment-these issues combine with others in my conclusion that Scientology remains a threat to the human rights of both its members and its opponents. 

BIBLIOGRAPHY

Abelson, Elliot J. (2002). "Re: Gerald Armstrong. Stephen A. Kent." [Correspondence]. Los Angeles: 1p.; Available at: < http://www.gerryarmstrong.org/50grand/cult/abelsonltr-kent-020605.html >.

Berlin State Court. (2001). "Robert S. Minton vs. Sabine Weber, Scientology Kirche Deutschland e.V. and Scientology Kirche Berlin e.V." Minton v. Scientology et al. (March 27).; Available at: <http://lisatrust.bogie.nl/legal/minton/berlin/4-01decision.html>.

Brown, Janelle. (1998). "A Web of Their Own." Salon (July 15); Downloaded from: <http://archive.salon.com/21st/feature/1998/07/15feature.html> on August 23, 2003.

California Court of Appeal, Second Appellate District, District Seven. (1989). "Larry Wollersheim v. Church of Scientology of California." (Filed July 19): 9269-9279.

CBS (1997). "CAN the Cult Awareness Network." 60 Minutes Transcript. Volume XXX No. 15: 15-22.

Church of Scientology International. (1995). "Anti-Religionists Face the End of the Road." International Scientology News: [21].

Church of Scientology International (CSI). (1998). "Slamming in Standard Ethics." High Winds: 16-19.

Circuit Court of the Sixth Judicial Circuit, Pinellas County, State of Florida. (2000). "Affidavit [by Stephen A. Kent] in Estate of Lisa McPherson . . . v. Church of Scientology Flag Service Organization . . . ." (January 6): 46 pp.; Downloaded from: <http://www.arts.ualberta.ca/~skent/Linkedfiles/mcpherson.htm> on January 10, 2003.

Coad, Malcolm. (1991). "Sympathy with the Devil." Weekend Guardian [UK]. (August 24-5): 12-13.

Collignon, Pierre. (2001a). "Cult Accused of Brainwashing." Jyllands-Posten [Copenhagen, Denmark]. Unofficial Anonymous English Translation. (January 14); Downloaded from <alt.religion.scientology> on July 30, 2001.

Collignon, Pierre. (2001b). "Franz the Happy." Jyllands-Posten [Copenhagen, Denmark]. Unofficial Anonymous English Translation. (January 14): Downloaded from <alt.religion.scientology> on July 30, 2001.

Collignon, Pierre. (2001c). "An Offer from Scientology." Jyllands-Posten[Copenhagen, Denmark]. Unofficial Translation by Jens Tingleff. (January 14); Downloaded from: < http://www.holysmoke.org/cos/rpf-denmark4.htm > on January 12, 2003.

Coser, Lewis. A. (1974). Greedy Institutions: Patterns of Undivided Commitment. New York: The Free Press.

Court of Appeal for Ontario. (1997). "Her Majesty the Queen (Respondent) and Church of Scientology of Toronto and Jacqueline Matz (Appelants) C13047, C13207." (April 18): 143pp; Available at: <http://xenu.ca/court/appeal.html >.

Frantz, Douglas (1997a). "Scientology's Puzzling Journey From Tax Rebel to Tax Exempt." New York Times (March 9): 1, 30-31.

Frantz, Douglas. (1997b). "Death of a Scientologist Heightens Suspicions in a Florida Town." New York Times (December 1): A1, A14.

Frantz, Douglas. (1999). "First Step, Get IRS Form 990's." The Nieman Foundation for Journalism at Harvard University, Second Watchdog Conference, Boston, Massachusetts.

Frantz, Douglas. (2000). [Apology to Dr. Stephen A. Kent]. Correspondence with Stephen A. Kent. 1p.

Gerstel, David U. (1982). Paradise, Incorporated: Synanon. Novato, California: Presidio Press. 

Goodman, Leisa. (2001). "A Letter from the Church of Scientology." Marburg Journal of Religion 6(2): 4 electronic pp.; Available at: <http://www.uni-marburg.de/religionswissenschaft/journal/mjr/goodman.html>.

Goodstein, Laurie. (1996). "Anti-Cult Group Dismembered as Former Foes buy Its Assets." Washington Post (December 1): A1, A22.

Gormez, Mike. (2002). "The Story of Vivien Krogmann-Lutz."

Downloaded from: <http://www.whyaretheydead.net/childabuse/vivien/?FACTNet> on August 23, 2003.

Heldal-Lund, Andreas. (2003). "Scientology Censor Software Cracked!"; Downloaded from: <http://www.xenu.net/archives/events/censorship/wordlist.html> on August 23, 2003.

Hubbard, L. Ron. (1967). "Organization Definition of." The Organization Executive Course 7. Los Angeles: Church of Scientology of California: 199.

Hubbard, L. Ron. (1970). "Stories Told." Sea Organization Flag Order 2673 (December 24): 1p.

Hubbard, L. Ron. (1976a). Modern Management Technology Defined. Copenhagen, New Era Publications.

Hubbard, L. Ron. (1976b). The Only Valid Security Check. The Technical Bulletins of Dianetics and Scientology IV. Copenhagen, Scientology Publications: 275-281.

International Association of Scientologists Administrations. (1995). "Mr. Kurt Weiland[:] Deputy Commanding Officer[,] Office of Special Affairs International." Impact: 10-13.

Janis, Mark: Richard S. Kay; and Anthony Bradley. (1995). European Human Rights Law: Text and Materials. Oxford, Clarendon Press.

Kent, Stephen A. (1998). ""Witness Statement of Stephen Alan Kent" in Bonnie Louise Woods, Plaintiff; and Sheila Chaleff, Graeme Wilson, Cathy Sproule, Church of Scientology Religious Education Inc., Defendants. 1993 W. No. 2079." 15pp.; Available at: <http://www.arts.ualberta.ca/~skent/Linkedfiles/bonniewood.htm

Kent, Stephen A. (1999a). "The Creation of 'Religious' Scientology." Religious Studies and Theology 18(2): 97-126; Available at: <http://www.holysmoke.org/cos/kent-fake-religion.htm>.

Kent, Stephen A. (1999b). "The Globalization of Scientology: Influence, Control and Opposition in Transnational Markets." Religion 29: 147-169; Available at: <http://www.gospelcom.net/apologeticsindex/s04a13.html>.

Kent, Stephen A. (1999c). "Scientology--Is this a Religion?" Marburg Journal of Religion 4(1): 1-11; Available at: <http://www.uni-marburg.de/religionswissenschaft/journal/mjr/kent.html>

Kent, Stephen A. (2000). Brainwashing in Scientology's Rehabilitation Project Force (RPF). Hamburg, Germany, Behörde für Inneres-Arbeitsgruppe Scientology und Landeszentrale für politische Bildung: 63pp.; Available at: <http://www.hamburg.de/Behoerden/ags/brain.pdf>.

Kent, Stephen A. (2001a). Brainwashing Programs in The Family/Children of God and Scientology. In Misunderstanding Cults: Searching for Objectivity in a Controversial Field. Eds. Benjamin Zablocki and Thomas Robbins. Toronto, University of Toronto Press: 349-378.

Kent, Stephen A. (2001b). Compelling Evidence: A Rejoinder to Lorne Dawson's Chapter. In Misunderstanding Cults: Searching for Objectivity in a Controversial Field. Eds. Benjamin Zablocki and Thomas Robbins. Toronto, University of Toronto Press: 401-411.

Kent, Stephen A. (2001c). "The French and German Versus American Debate Over 'New Religions', Scientology, and Human Rights." Marburg Journal of Religion 6(1): 1-11; Available at: <http://www.uni-marburg.de/religionswissenschaft/journal/mjr/kent2.html>.

Kent, Stephen A. and Deana Hall. (2000). "Brainwashing and Re-Indoctrination Programs in the Children of God/The Family." Cultic Studies Journal 17: 56-78; Available at: <http://www.arts.ualberta.ca/~skent/Linkedfiles/cog_brainwashing.htm>.

Kent, Stephen A. and Theresa Krebs. (1998a). "Academic Compromise in the Social Scientific Study of Alternative Religions." Nova Religio 2(1): 44-54.

Kent, Stephen A. and Theresa Krebs. (1998b). "When Scholars Know Sin: Alternative Religions and Their Academic Supporters." Skeptic 6(3): 36-44; Available at: <http://www.gospelcom.net/apologeticsindex/c25.html>.

KOTO. (1989). First part of Series by Larry Blunt on Narconon. Oklahoma City, Oklahoma(August 21?).

Kumar, J. P. (1997). "'Fair Game': Leveling the Playing Field in Scientology Litigation." The Review of Litigation 16(3): 747-772.

Lattin, Don. (2001). "Leaving the Fold: Third Generation Scientologist Grows Disillusioned With Faith." San Francisco Chronicle (February 12); Available at: <http://www.gospelcom.net/apologeticsindex/c25.html>.

Lifton, Robert Jay. (1961). Thought Reform and the Psychology of Totalism: A Study of 'Brainwashing' in China. London, Victor Gollancz Ltd.

Los Angeles Times . (2002). "Scientologists Settle Suit By Ex-Member." (May 11).

Malka, Cyril. (2002). "Starved to Death in Denmark." et-sect-era Internet English Translation. (September12).

Melton, J. Gordon. (1999). "Mea Culpa! Mea Culpa!" Skeptic 7(1): 14-17; Available at: <http://www.gospelcom.net/apologeticsindex/c36.html>.

Melton, J. Gordon. (2001). "A Contemporary Ordered Religious Community: The Sea Organization." Paper Presented at the 2001 CESNUR Conference, London, England; Available at: <http://religiousmovements.lib.virginia.edu/cesnur/melton.html>.

Miller, Russell. (1987). Bare-Faced Messiah. The True Story of L. Ron Hubbard. London, Michael Joseph.

New York Times. (1979). "Author of a Book on Scientology Tells of Her 8 Years of Torment." (January 22).

Pentikainen, Juha and Marja Pentikainen. 1996. "The Church of Scientology." Report (January); Available at: http://www.neuereligion.de/ENG/Pentikainen/main.htm>.

Pentikainen, Juha: Jurgen F. K. Redhardt; and Michael York. (2002). "The Church of Scientology's Rehabilitation Project Force." Report; Available at: <http://www.cesnur.org/2002/scient_rpf_notes.htm>.

Reader, Ian. (2000). "Scholarship, Aum Shinrikyo, and Academic Integrity." Nova Religio 3: 368-382.

Rosenblum, Anne (n.d.). Declaration from Anne Rosenblum, Foreward by Dennis Erlich. 9pp.; Downloaded from http://wpxx02.toxiuni.wuerzburg.de/~kra-sel/CoS/affar.htm.

Rusnell, Charles. (1998). "Church of Scientology Targets U of A [University of Alberta] Professor for Criticizing its Practices." The Edmonton Journal [Canada]. (June 13): B7.

Schoen, Brigitte. (2002). "Reconstructing Reality from Highly Deviant Perspectives: A Reply to "'Verfassungsfeindlich': Church, State, and New Religions in Germany" by Irving Hexham and Karla Poewe." Nova Religio 6(1): 102-118.

Taylor, Greg. 2003. "New Case" [e-mail Correspondence With Author]. (February 26): 1p.

Taylor, Greg. Forthcoming. "Scientology in the German Courts." Journal of Law and Religion.

United Nations General Assembly. (1959). Declaration of the Rights of the Child; Available at: <http://www.hri.ca/uninfo/treaties/25.shtml>.

United States Claims Court. (1992). "Church of Spiritual Technology v. The United States." No. 581-887. (June 29): 32pp.; Available at: <http://www.xenu.net/archive/CourtFiles/occf72.html>.

United States Court of Appeals for the Ninth Circuit. 2002. "Michael Sklar; Marla Sklar, Petitioners-Appellants." Opinion. No. 00-70753, Tax Ct. No. 1556-97 (Filed January 29); Available at: <http://www.giftlaw.com/code.asp?U=2&W=102>.

Wallis, Roy. (1973). "Religious Sects and the Fear of Publicity." New Society: 52-54.

Wallis, Roy. (1976). The Road to Total Freedom: A Sociological Analysis of Scientology. New York, Columbia University Press.

Weinstein, Henry. (2002). "Couple Lose Bid for Tax Refund Tied to Tuition." Los Angeles Times. (January 30): B7.  

  ¹ In the Religion article, I cited the labour court case as: AP5 ArbGG 1979 Nr.21 [22.3.1995]. Subsequently I discovered that the simpler citation of it is NJW 1996, 143. This second, simpler citation appears in three cases that Scientology critic, Tilman Hausherr, has reproduced in the "Court Rulings on Scientology in Germany" section of his web site < http://home.snafu.de/tilman/krasel/germany/rulings.html > The cases are: OVG Münster, 5 B 993/95; VGH Baden-Würtemberg 10 S 176/96; and VGH Baden-Württemberg 5S 472/96. I understand, however, from the Australian scholar of the German legal system, Greg Taylor, that the Federal Labour Court (NJW 2003, 161; decided 26 September 2002) "does not follow its earlier decision BAGE 79, 319=NJW 1996, 143, and holds that a Scientologist working for Scientology WAS NOT in a relationship of employment. Nor does the Court say that Scientology is not a religion, as the earlier decision did, but leaves this question open" (Taylor, 2003). I express my gratitude to Dr. Taylor for this information.

Copyright © Stephen A. Kent 2003
First published in Marburg Journal of Religion