The Court directed that the parties address three issues in a supplemental briefing: “(1) whether, in light of Van Vliet v Vander Naald, 290 Mich 365 (1939), Westerhouse v De Witt, 215 Mich 295 (1921), and Howard v Dickie, 120 Mich 238 (1899), the reciprocal duty or interest giving rise to the qualified privilege at issue in this case applies to all church members generally, or only to members who are decision makers engaged in… [read post]