Courts decide cases based on the specific complaints filed and arguments offered, not some broad sense of wounded justice. The arguments made did not support the original complaints filed, so the court had no justifiable basis for finding on behalf of the Headley's.
Of a separate but related issue, two aspects of those findings which I find of particular interest.
From HEADLEY v. CHURCH OF SCIENTOLOGY
Citation of legal precedent of why 'disconnection' is not illegal. Of interest as a reference particularly for those who think it should be.... A church is entitled to stop associating with someone who abandons it. Paul v. Watchtower Bible & Tract Soc’y of N.Y., Inc., 819 F.2d 875, 883 (9th Cir. 1987) (holding that the free exercise clause protects the practice of shunning, explaining that when “[t]he members of [a] [c]hurch” “no longer want to associate with” someone who has “abandon[ed]” them, those members “are free” under the First Amendment “to make that choice”). A church may also warn that it will stop associating with members who do not HEADLEY v. CHURCH OF SCIENTOLOGY 8409act in accordance with church doctrine. The former is a legitimate consequence, the latter a legitimate warning. Cf. Bradley, 390 F.3d at 151.
IV, A, 3 ...
... Likewise, we do not decide how the Headleys might have fared under a different statute or on other legal theories. The Headleys abandoned claims under federal and state minimum wage laws. And although the Headleys marshaled evidence of potentially tortious conduct, they did not bring claims for assault, battery, false imprisonment, intentional infliction of emotional distress, or any of a number of other theories that might have better fit the evidence. The Headleys thus wagered
all on a statute enacted “to combat” the “transnational crime” of “trafficking in persons”—particularly defenseless, vulnerable immigrant women and children. 22 U.S.C. § 7101(a), (b)(24); see id. § 7101(b)(1), (2), (4), (17), (22). Whatever bad
acts the defendants (or others) may have committed, the record does not allow the conclusion that the Church or the Center violated the Trafficking Victims Protection Act.
IV, B, 5 ...
What is of interest is how the appeals court spells out how the arguments made might be taken to support complaints filed on different bases. That is not material that the court is required to provide. Consider it a form of indirect yet informative provision of legal insight & education. Certainly it is useful to law students and any lawyers representing clients with similar claims.
Mark A. Baker