Iowa Supreme Court: Satan's secular connotations mean church member can sue over letter
Is the spirit of Satan at work in Shell Rock United Methodist Church? The Rev. Jerrold Swinton, a district supervisor for the Iowa Conference of the United Methodist Church, thought so when he visited the congregation in March 1999 to investigate "reports of strife." And he said as much in a letter to the congregation (which also went to members of the Shell Rock community). "A few months ago I attended worship in Shell Rock and I rejoiced to see so many young families in church. I was in despair when Jane Kliebenstein made an effort to whisper scornfully to me that this pastor must leave Shell Rock," he wrote.

Folks, when is enough, enough?  When will you stop the blaming, negative and unhappy persons among you from tearing down the spirit of Jesus Christ among you? … You know whether a person has the spirit of Jesus or Satan by their fruits. … I am distressed and perplexed why people have tolerance and compassion for anyone who habitually tears down the Body of Christ by habitually sowing discord and pain. … When the congregation of Shell Rock is ready to acknowledge they allowed the spirit of Satan to work in their midst, express some contrition and seek help—then help will come.

Swinton recommended that a church conference be called over the matter to "propose that Jane Kliebenstein be stripped of church offices.  It is understood that if she continues to cause dissension, she will next be asked to leave the Shell Rock UMC."

Kliebenstein filed a civil suit, claiming that the letter defamed her integrity and moral character. A district court thew out the suit, saying it didn't have the jurisdiction to adjudicate the impact of a "purely ...