Religious Institutions Update: June 2017

Holland & Knight LLP

Holland & Knight LLP

Timely Topics

The U.S. Supreme Court recently heard oral argument in Trinity Lutheran Church of Columbia, Inc. v. Comer, No. 15-577. The lawsuit concerns whether the daycare operated by a Missouri church may qualify for a state program that reimburses nonprofits for the purchase and installation of a rubber playground surface. Justice Ruth Bader Ginsburg asked a question that frames much of the current debate about religious freedom. She observed that the daycare in Trinity Lutheran has a nondiscriminatory admissions policy. "But suppose it didn't?" Justice Ginsburg asked. "Suppose its policy was we prefer Lutheran children, and then if we have any space left over after that, we'll take other Christians. And then after that, maybe Jews, and then everyone else.... Could ... they demand as a matter of Federal constitutional right that that playground be funded, even though they have an ... admissions policy that favors members of their church?" Tr. 12:10-21. The church responded affirmatively based on what it described as a free exercise right to religious autonomy to decide who are its members. Tr. 12:22-13:11. The church summarized the state's discretion this way: The state does not have to set up the program in the first place or could make government schools the exclusive beneficiaries, "but once it sets up the program to include all" not-for-profit preschools based on certain criteria that a religious organization meets, the state cannot discriminate against the religious organization irrespective of its admissions policy. Tr. 27:10-28:5. As Justice Ginsburg's question indicates, some jurists disagree and want to condition a religious organization's participation in public programs or even a religious organization's tax-exempt operations on popular conceptions of the good not always in line with a religious organization's theology; for example, by requiring open admissions or open employment or by curtailing its speech. Other Americans want to exclude religious organizations from public programs merely because they are religious. These views may be gaining ground, so religious organizations are wise to engage in compliance planning now before they are caught in the movement's crosshairs.

Key Cases

EO Temporarily Suspending Immigration Enjoined Under Establishment Clause

In International Refugee Assistance Project v. Trump, No. 17-1351, 2017 WL 2273306 (4th Cir. May 25, 2017), the court of appeals affirmed in part and vacated in part the district court's nationwide preliminary injunction on Establishment Clause grounds against the president's second executive order (EO) temporarily suspending immigration from six predominately Muslim countries (i.e., Iran, Libya, Somalia, Sudan, Syria and Yemen) with known ties to terrorism. The individual plaintiffs are U.S. citizens or lawful permanent residents who have sponsored relatives who are citizens of one of the designated countries and seek immigrant visas to enter the U.S. The court determined that the EO injured them as a result of their separation from family members. It considered their claim that the alleged "official anti-Muslim sentiment" expressed in the EO caused them mental stress and rendered them "isolated and disparaged," sufficient to state an Establishment Clause claim. In assessing an Establishment Clause burden, governmental statements of purpose generally receive deference, but in this case, the court ruled it was appropriate to look at the motives for the EO, including the sequence of events leading up to it, such as President Donald Trump's first EO as well as public statements he made during his presidential candidacy. According to the district court, these include "explicit, direct statements of President Trump's animus towards Muslims...." The government protested that many of the statements were made before President Trump became a government official, but the court considered them relevant anyway. Furthermore, the court viewed the government's claim that national security is the primary purpose of the EO as, at best, a "post hoc, secondary justification for an executive action rooted in religious animus."

Denying Custom Floral Arrangement to Same-Sex Couple Violated Law

In State v. Arlene's Flowers, Inc., 187 Wash. 2d 804 (Wash. 2017), the court ruled that the defendants, a Southern Baptist and her floral company, discriminated on the basis of sexual orientation by refusing on the basis of religious convictions to provide custom floral arrangements for a same-sex wedding in violation of the Washington Law Against Discrimination (WLAD). The court also ruled that the owner was per se personally liable under the Consumer Protection Act (CPA). The court ruled that WLAD is a neutral, generally applicable law with a rational basis; and, thus, its enforcement was not in violation of the defendant's free exercise rights. The court added that WLAD would be consistent with the First Amendment even if strict scrutiny applied and rejected the defendant's argument that the company's floral arrangements were a form of protected "expression" under the Free Speech Clause. The court also ruled that the defendant stated no free association claim against application of the WLAD or CPA.

No Claim Against Church for Publishing Baptism Allegedly Leading to Kidnapping and Torture

In Doe v. First Presbyterian Church U.S.A. of Tulsa, Oklahoma, No. 115182, 2017 WL 1332134 (Okla. Feb. 22, 2017), the court ruled that the church autonomy doctrine precludes the plaintiff's breach of contract and tort action against First Presbyterian Church for publication of his baptism, allegedly leading to his kidnapping and torture by extremists in Syria. Although a nonmember, the plaintiff volunteered for baptism but alleged that he made the church aware of the need for confidentiality. Immediately after his baptism, the plaintiff traveled to Syria. Radical Muslims who had learned of his conversion on the internet kidnapped, tortured and threatened to kill him. The plaintiff escaped and returned clandestinely to the U.S. He sued the church for breach of contract, negligence and outrage. The church argued that the public nature of baptism is an integral part of its understanding of the sacrament. As a result, the court determined that the plaintiff's claims were predicated on religious belief, and, therefore, the church autonomy doctrine precluded the subject's claims.

Ecclesiastical Abstention Doctrine Precludes Student's Claims Against College

In Doe v. Pontifical College Josephinum, No. 16AP-300, 2017 WL 1180661 (Ohio App. Mar. 30, 2017), the court of appeals affirmed the lower court's ruling that it lacked jurisdiction over a student's breach of contract, intentional infliction of emotional distress, unauthorized disclosure of educational records and unjust enrichment claims against the pontifical college where he was enrolled. The college expelled him pursuant to an investigation in which the vice rector determined that the student was involved in homosexual activity. The court determined that the legal questions presented were inextricably intertwined with the underlying disciplinary process that led to his expulsion.

Judge Censured for Not Performing Same-Sex Marriages

In In re Neely, 390 P. 3d 728 (Wyo. Mar. 7, 2017), the Supreme Court of Wyoming ruled that disciplining a judge who stated she would not be able to perform same-sex marriages based on her religious convictions serves the compelling state interest of maintaining public confidence in the judiciary. Judge Ruth Neely is a Christian and member of the Lutheran Church, Missouri Synod. As a judge, she may perform, but is not required to perform, marriage ceremonies. Against Judge Neely's First Amendment defenses, the court ruled that the state has a compelling interest in maintaining public confidence in the judiciary by enforcing the rules requiring independence and impartiality. The court ruled that Judge Neely violated several rules of judicial conduct, including the obligation to promote confidence in the judiciary, to uphold the law impartially and with fairness, and not to manifest bias, prejudice or harassment. As punishment, the court called for public censure and has required Judge Neely either not to perform any marriage ceremonies or to perform them regardless of a couple's sexual orientation.

Fair Housing Act Injunction Entered Due to Religious Discrimination

In United States v. Town of Colorado City, Arizona, No. 3:12-v-8123-HRH, 2017 WL 1384353 (D. Ariz. Ap. 18, 2017), the court entered an extensive injunction in connection with the denial of housing rights and unlawful policing of residents at the behest of the Fundamentalist Church of Jesus Christ of Latter Day Saints (FLDS). Specifically, the court found that Colorado City and the City of Hildale, Utah, engaged in a pattern or practice of discriminating against non-FLDS individuals under pressure from the FLDS in the terms, conditions or privileges of the sale or rental of dwellings and coercing, intimidating, threatening or interfering with individuals in the exercise of enjoyment of the right to equal housing opportunities in violation of the Fair Housing Act.

RFRA Claims Stated Due to Rezoning Denial and Refusal to Permit Demolition

In Village of West Dundee v. First United Methodist Church of West Dundee, No. 2-15-0278 (Ill.App. 2d Dist. Mar. 7, 2017), the defendant complained that the city denied it a permit to demolish an abandoned historic building for increased parking while issuing demolition permits for at least three other structures in the Historic District. In a cross-complaint, the defendant argued that this violated the Religious Land Use and Institutionalized Persons Act (RLUIPA) and amounted to inverse condemnation or a "taking." The court of appeal vacated judgment against the defendant in circuit court, including an order that if the church did not repair the building within 14 days, the village was authorized to undertake the repairs and to place a lien on the property for the costs. The plaintiff argued that the defendant had not exhausted its administrative remedies before filing its RLUIPA counterclaim, but the appeals court dispatched with this argument in circumstances where the plaintiff instituted the court proceedings by bringing an action for code enforcement. Next, the appeals court credited the defendant's argument that repairing the building would be financially ruinous and, thus, that refusing demolition amounted to a substantial burden on the defendant's free exercise of its religion. The court also agreed that the church stated a claim for unequal treatment under RLUIPA, as well as inverse condemnation.

Ecclesiastical Abstention Doctrine Applies to Pastor's Claims Against His Church

In Speller v. St. Stephen Lutheran Church of Drayton Plains, No. 330739, 2017 WL 1190933 (Mich.App. Mar. 28, 2017), a pastor filed an eight-count complaint against his former church for alleged wrongful conduct in attempting to oust him, which he claims led to his "blacklisting" in the church and an inability to practice his profession as a Lutheran pastor. The court disagreed with him that this matter could be resolved by applying neutral principles of law. It ruled that the complaint "essentially presents an internal church dispute between the church and plaintiff relating to his status and employment" and implicates the church's constitution and bylaws, subjective judgments of religious officials and governing bodies concerning his performance as pastor, defendants' alleged wrongful conduct in attempting to circumvent the church rules to oust him, internal church communications and the disciplinary action taken against him by the church. "Resolution of these matters would necessarily require the court to stray into matters of internal church governance and discipline, which are not subjects over which a civil court has jurisdiction."

Courts Adopt Differing Approaches to Church Property Disputes

Hierarchical Deference Approach Applied

In Heartland Presbytery v. Presbyterian Church of Stanley, Inc., 390 P. 3d 581 (Kans. App. 2017), the court affirmed the lower court's ruling that the internal rules of the Presbyterian Church U.S.A. (PCUSA) control a property dispute between the hierarchical denomination and a local church congregation after a majority of the congregation voted to leave the denomination over certain theological differences relating to, inter alia, the divinity of Jesus Christ, the exclusivity of Christianity for salvation and the authority of Scriptures. The court ruled that the district court properly applied the principle of hierarchical deference, which is the doctrine that deference should be given to the highest church body to which an issue has been presented. That body determined that the members of the staying faction who desire to continue their affiliation with the denomination are entitled to the disputed property. But even if the neutral principles of law approach applied, the court ruled that the Book of Order's requirement that the property be held in trust for the use and benefit of PCUSA should control the disposition of the property. The court did not find for PCUSA that the appellants waived their right to appeal by relinquishing their membership in the church and joining another church.   

Neutral Principles of Law Applied

In Presbytery of the Twin Cities Area v. Eden Prairie Presbyterian Church, Inc., No. A16-0945, 2017 WL 1436050 (Minn. App. Ap. 24, 2017), the court determined that it could decide a dispute between PCUSA and another congregation under a neutral principles of law approach and ruled in favor of the congregation. The court decided that it was proper to decide the lawsuit because earlier versions of the Book of Order did not contain a clause found in the newest version stating that property is a tool for the accomplishment of the mission of Jesus Christ in the world and because "there is no evidence that otherwise suggests that the property dispute poses a question of church doctrine or polity." Additionally, the court cautioned generally against "compulsory deference to religious authority in resolving church property disputes." The court went on to decide that by amendment of its bylaws adopting trust language contained in the Book of Order, the congregation agreed to hold its property in trust for the use and benefit of PCUSA; however, the church retained the right in its articles of incorporation to amend those bylaws and did so to revoke the trust and remove all trust language.

Religious Institutions in the News

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Holland & Knight LLP | Attorney Advertising

Written by:

Holland & Knight LLP

Holland & Knight LLP on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:
*By using the service, you signify your acceptance of JD Supra's Privacy Policy.
Custom Email Digest
- hide

JD Supra Privacy Policy

Updated: May 25, 2018:

JD Supra is a legal publishing service that connects experts and their content with broader audiences of professionals, journalists and associations.

This Privacy Policy describes how JD Supra, LLC ("JD Supra" or "we," "us," or "our") collects, uses and shares personal data collected from visitors to our website (located at (our "Website") who view only publicly-available content as well as subscribers to our services (such as our email digests or author tools)(our "Services"). By using our Website and registering for one of our Services, you are agreeing to the terms of this Privacy Policy.

Please note that if you subscribe to one of our Services, you can make choices about how we collect, use and share your information through our Privacy Center under the "My Account" dashboard (available if you are logged into your JD Supra account).

Collection of Information

Registration Information. When you register with JD Supra for our Website and Services, either as an author or as a subscriber, you will be asked to provide identifying information to create your JD Supra account ("Registration Data"), such as your:

  • Email
  • First Name
  • Last Name
  • Company Name
  • Company Industry
  • Title
  • Country

Other Information: We also collect other information you may voluntarily provide. This may include content you provide for publication. We may also receive your communications with others through our Website and Services (such as contacting an author through our Website) or communications directly with us (such as through email, feedback or other forms or social media). If you are a subscribed user, we will also collect your user preferences, such as the types of articles you would like to read.

Information from third parties (such as, from your employer or LinkedIn): We may also receive information about you from third party sources. For example, your employer may provide your information to us, such as in connection with an article submitted by your employer for publication. If you choose to use LinkedIn to subscribe to our Website and Services, we also collect information related to your LinkedIn account and profile.

Your interactions with our Website and Services: As is true of most websites, we gather certain information automatically. This information includes IP addresses, browser type, Internet service provider (ISP), referring/exit pages, operating system, date/time stamp and clickstream data. We use this information to analyze trends, to administer the Website and our Services, to improve the content and performance of our Website and Services, and to track users' movements around the site. We may also link this automatically-collected data to personal information, for example, to inform authors about who has read their articles. Some of this data is collected through information sent by your web browser. We also use cookies and other tracking technologies to collect this information. To learn more about cookies and other tracking technologies that JD Supra may use on our Website and Services please see our "Cookies Guide" page.

How do we use this information?

We use the information and data we collect principally in order to provide our Website and Services. More specifically, we may use your personal information to:

  • Operate our Website and Services and publish content;
  • Distribute content to you in accordance with your preferences as well as to provide other notifications to you (for example, updates about our policies and terms);
  • Measure readership and usage of the Website and Services;
  • Communicate with you regarding your questions and requests;
  • Authenticate users and to provide for the safety and security of our Website and Services;
  • Conduct research and similar activities to improve our Website and Services; and
  • Comply with our legal and regulatory responsibilities and to enforce our rights.

How is your information shared?

  • Content and other public information (such as an author profile) is shared on our Website and Services, including via email digests and social media feeds, and is accessible to the general public.
  • If you choose to use our Website and Services to communicate directly with a company or individual, such communication may be shared accordingly.
  • Readership information is provided to publishing law firms and authors of content to give them insight into their readership and to help them to improve their content.
  • Our Website may offer you the opportunity to share information through our Website, such as through Facebook's "Like" or Twitter's "Tweet" button. We offer this functionality to help generate interest in our Website and content and to permit you to recommend content to your contacts. You should be aware that sharing through such functionality may result in information being collected by the applicable social media network and possibly being made publicly available (for example, through a search engine). Any such information collection would be subject to such third party social media network's privacy policy.
  • Your information may also be shared to parties who support our business, such as professional advisors as well as web-hosting providers, analytics providers and other information technology providers.
  • Any court, governmental authority, law enforcement agency or other third party where we believe disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights, the rights of any third party or individuals' personal safety, or to detect, prevent, or otherwise address fraud, security or safety issues.
  • To our affiliated entities and in connection with the sale, assignment or other transfer of our company or our business.

How We Protect Your Information

JD Supra takes reasonable and appropriate precautions to insure that user information is protected from loss, misuse and unauthorized access, disclosure, alteration and destruction. We restrict access to user information to those individuals who reasonably need access to perform their job functions, such as our third party email service, customer service personnel and technical staff. You should keep in mind that no Internet transmission is ever 100% secure or error-free. Where you use log-in credentials (usernames, passwords) on our Website, please remember that it is your responsibility to safeguard them. If you believe that your log-in credentials have been compromised, please contact us at

Children's Information

Our Website and Services are not directed at children under the age of 16 and we do not knowingly collect personal information from children under the age of 16 through our Website and/or Services. If you have reason to believe that a child under the age of 16 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases.

Links to Other Websites

Our Website and Services may contain links to other websites. The operators of such other websites may collect information about you, including through cookies or other technologies. If you are using our Website or Services and click a link to another site, you will leave our Website and this Policy will not apply to your use of and activity on those other sites. We encourage you to read the legal notices posted on those sites, including their privacy policies. We are not responsible for the data collection and use practices of such other sites. This Policy applies solely to the information collected in connection with your use of our Website and Services and does not apply to any practices conducted offline or in connection with any other websites.

Information for EU and Swiss Residents

JD Supra's principal place of business is in the United States. By subscribing to our website, you expressly consent to your information being processed in the United States.

  • Our Legal Basis for Processing: Generally, we rely on our legitimate interests in order to process your personal information. For example, we rely on this legal ground if we use your personal information to manage your Registration Data and administer our relationship with you; to deliver our Website and Services; understand and improve our Website and Services; report reader analytics to our authors; to personalize your experience on our Website and Services; and where necessary to protect or defend our or another's rights or property, or to detect, prevent, or otherwise address fraud, security, safety or privacy issues. Please see Article 6(1)(f) of the E.U. General Data Protection Regulation ("GDPR") In addition, there may be other situations where other grounds for processing may exist, such as where processing is a result of legal requirements (GDPR Article 6(1)(c)) or for reasons of public interest (GDPR Article 6(1)(e)). Please see the "Your Rights" section of this Privacy Policy immediately below for more information about how you may request that we limit or refrain from processing your personal information.
  • Your Rights
    • Right of Access/Portability: You can ask to review details about the information we hold about you and how that information has been used and disclosed. Note that we may request to verify your identification before fulfilling your request. You can also request that your personal information is provided to you in a commonly used electronic format so that you can share it with other organizations.
    • Right to Correct Information: You may ask that we make corrections to any information we hold, if you believe such correction to be necessary.
    • Right to Restrict Our Processing or Erasure of Information: You also have the right in certain circumstances to ask us to restrict processing of your personal information or to erase your personal information. Where you have consented to our use of your personal information, you can withdraw your consent at any time.

You can make a request to exercise any of these rights by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

You can also manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard.

We will make all practical efforts to respect your wishes. There may be times, however, where we are not able to fulfill your request, for example, if applicable law prohibits our compliance. Please note that JD Supra does not use "automatic decision making" or "profiling" as those terms are defined in the GDPR.

  • Timeframe for retaining your personal information: We will retain your personal information in a form that identifies you only for as long as it serves the purpose(s) for which it was initially collected as stated in this Privacy Policy, or subsequently authorized. We may continue processing your personal information for longer periods, but only for the time and to the extent such processing reasonably serves the purposes of archiving in the public interest, journalism, literature and art, scientific or historical research and statistical analysis, and subject to the protection of this Privacy Policy. For example, if you are an author, your personal information may continue to be published in connection with your article indefinitely. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
  • Onward Transfer to Third Parties: As noted in the "How We Share Your Data" Section above, JD Supra may share your information with third parties. When JD Supra discloses your personal information to third parties, we have ensured that such third parties have either certified under the EU-U.S. or Swiss Privacy Shield Framework and will process all personal data received from EU member states/Switzerland in reliance on the applicable Privacy Shield Framework or that they have been subjected to strict contractual provisions in their contract with us to guarantee an adequate level of data protection for your data.

California Privacy Rights

Pursuant to Section 1798.83 of the California Civil Code, our customers who are California residents have the right to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

You can make a request for this information by emailing us at or by writing to us at:

Privacy Officer
JD Supra, LLC
10 Liberty Ship Way, Suite 300
Sausalito, California 94965

Some browsers have incorporated a Do Not Track (DNT) feature. These features, when turned on, send a signal that you prefer that the website you are visiting not collect and use data regarding your online searching and browsing activities. As there is not yet a common understanding on how to interpret the DNT signal, we currently do not respond to DNT signals on our site.

Access/Correct/Update/Delete Personal Information

For non-EU/Swiss residents, if you would like to know what personal information we have about you, you can send an e-mail to We will be in contact with you (by mail or otherwise) to verify your identity and provide you the information you request. We will respond within 30 days to your request for access to your personal information. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why. If you would like to correct or update your personal information, you can manage your profile and subscriptions through our Privacy Center under the "My Account" dashboard. If you would like to delete your account or remove your information from our Website and Services, send an e-mail to

Changes in Our Privacy Policy

We reserve the right to change this Privacy Policy at any time. Please refer to the date at the top of this page to determine when this Policy was last revised. Any changes to our Privacy Policy will become effective upon posting of the revised policy on the Website. By continuing to use our Website and Services following such changes, you will be deemed to have agreed to such changes.

Contacting JD Supra

If you have any questions about this Privacy Policy, the practices of this site, your dealings with our Website or Services, or if you would like to change any of the information you have provided to us, please contact us at:

JD Supra Cookie Guide

As with many websites, JD Supra's website (located at (our "Website") and our services (such as our email article digests)(our "Services") use a standard technology called a "cookie" and other similar technologies (such as, pixels and web beacons), which are small data files that are transferred to your computer when you use our Website and Services. These technologies automatically identify your browser whenever you interact with our Website and Services.

How We Use Cookies and Other Tracking Technologies

We use cookies and other tracking technologies to:

  1. Improve the user experience on our Website and Services;
  2. Store the authorization token that users receive when they login to the private areas of our Website. This token is specific to a user's login session and requires a valid username and password to obtain. It is required to access the user's profile information, subscriptions, and analytics;
  3. Track anonymous site usage; and
  4. Permit connectivity with social media networks to permit content sharing.

There are different types of cookies and other technologies used our Website, notably:

  • "Session cookies" - These cookies only last as long as your online session, and disappear from your computer or device when you close your browser (like Internet Explorer, Google Chrome or Safari).
  • "Persistent cookies" - These cookies stay on your computer or device after your browser has been closed and last for a time specified in the cookie. We use persistent cookies when we need to know who you are for more than one browsing session. For example, we use them to remember your preferences for the next time you visit.
  • "Web Beacons/Pixels" - Some of our web pages and emails may also contain small electronic images known as web beacons, clear GIFs or single-pixel GIFs. These images are placed on a web page or email and typically work in conjunction with cookies to collect data. We use these images to identify our users and user behavior, such as counting the number of users who have visited a web page or acted upon one of our email digests.

JD Supra Cookies. We place our own cookies on your computer to track certain information about you while you are using our Website and Services. For example, we place a session cookie on your computer each time you visit our Website. We use these cookies to allow you to log-in to your subscriber account. In addition, through these cookies we are able to collect information about how you use the Website, including what browser you may be using, your IP address, and the URL address you came from upon visiting our Website and the URL you next visit (even if those URLs are not on our Website). We also utilize email web beacons to monitor whether our emails are being delivered and read. We also use these tools to help deliver reader analytics to our authors to give them insight into their readership and help them to improve their content, so that it is most useful for our users.

Analytics/Performance Cookies. JD Supra also uses the following analytic tools to help us analyze the performance of our Website and Services as well as how visitors use our Website and Services:

  • HubSpot - For more information about HubSpot cookies, please visit
  • New Relic - For more information on New Relic cookies, please visit
  • Google Analytics - For more information on Google Analytics cookies, visit To opt-out of being tracked by Google Analytics across all websites visit This will allow you to download and install a Google Analytics cookie-free web browser.

Facebook, Twitter and other Social Network Cookies. Our content pages allow you to share content appearing on our Website and Services to your social media accounts through the "Like," "Tweet," or similar buttons displayed on such pages. To accomplish this Service, we embed code that such third party social networks provide and that we do not control. These buttons know that you are logged in to your social network account and therefore such social networks could also know that you are viewing the JD Supra Website.

Controlling and Deleting Cookies

If you would like to change how a browser uses cookies, including blocking or deleting cookies from the JD Supra Website and Services you can do so by changing the settings in your web browser. To control cookies, most browsers allow you to either accept or reject all cookies, only accept certain types of cookies, or prompt you every time a site wishes to save a cookie. It's also easy to delete cookies that are already saved on your device by a browser.

The processes for controlling and deleting cookies vary depending on which browser you use. To find out how to do so with a particular browser, you can use your browser's "Help" function or alternatively, you can visit which explains, step-by-step, how to control and delete cookies in most browsers.

Updates to This Policy

We may update this cookie policy and our Privacy Policy from time-to-time, particularly as technology changes. You can always check this page for the latest version. We may also notify you of changes to our privacy policy by email.

Contacting JD Supra

If you have any questions about how we use cookies and other tracking technologies, please contact us at:

- hide

This website uses cookies to improve user experience, track anonymous site usage, store authorization tokens and permit sharing on social media networks. By continuing to browse this website you accept the use of cookies. Click here to read more about how we use cookies.