## Facts

- Religious Technology Center and Church of Scientology International claimed ownership and control of confidential, higher-level Scientology materials used in religious instruction.
- A breakaway group, Church of the New Civilization, and associated individuals allegedly possessed and used copies of those materials in their own services.
- The materials were alleged to have been stolen from a Scientology office in Denmark and later surfaced in connection with discovery in separate litigation involving former adherent Larry Wollersheim.
- Plaintiffs sued in federal district court asserting (1) a private civil RICO claim and (2) a California trade secret misappropriation claim, seeking to stop further use and dissemination.
- The district court issued a preliminary injunction barring defendants from using or disseminating the disputed materials, reasoning that RICO jurisdiction existed and that the materials were protectable as trade secrets.
- Defendants appealed the preliminary injunction.

## Issues

1. Whether a private plaintiff may obtain injunctive relief under civil RICO, 18 U.S.C. § 1964.
2. Whether confidential religious “scriptural materials” qualify as “trade secrets” under California law such that injunctive relief may issue.

## Decision

- The Ninth Circuit reversed the preliminary injunction and remanded.
- The court held that injunctive relief is not available to private plaintiffs under civil RICO.
- The court held that California courts would not treat sacred religious scriptures as trade secrets under California trade secret law.
- Because neither asserted theory supported equitable relief, the preliminary injunction could not stand.

## Legal Principles

- Civil RICO’s express authorization of equitable relief for the government, coupled with § 1964(c)’s express private damages remedy and silence on injunctions, indicates Congress did not provide private injunctive relief under RICO.
- Courts should not imply private equitable remedies under RICO beyond the remedies Congress specified.
- Under California trade secret doctrine, protection is directed to commercial information with independent economic value from secrecy and subject to reasonable secrecy measures; religious doctrinal texts are not treated as “trade secrets” in the ordinary commercial sense for injunctive enforcement.

## Conclusion

The Ninth Circuit vacated a preliminary injunction sought to prevent use and dissemination of confidential religious materials, ruling that private parties cannot obtain injunctive relief under civil RICO and that California trade secret law does not extend to sacred scriptures as trade secrets.


Religious Tech. Ctr. v. Wollersheim, 796 F.2d 1076 (9th Cir. 1986)