In Weaver & Wood, in 1996, the plaintiffs, Elizabeth Weaver and Roy Varner, did not have standing because they alleged no violation of civil law or public policy, nor of any rights personal to themselves. There were no allegations of fraud or corrupt self-dealing.

It was pre-agreed, in Weaver & Wood, that only the 1892 and 1898 deeds of trust be placed before the court. The critical 1903 deed agreement — specifying that no changes or annulments be made in the church manual — was intentionally not presented to the court.

The five man temporary board of directors under the church manual was presented to the court as the four man self-perpetuating board of trustees under the 1892 deed of trust.

In such cases of misrepresentation (deceit), the First Amendment would not bar civil court jurisdiction.

The First Amendment does not bar the prosecution of religious leaders for fraud.