Though another fraud lawsuit against leaders of Utah’s predominant faith has been rejected on appeal, key legal questions are likely to linger.

The latest federal case denied by the courts was filed in 2019 against The Church of Jesus Christ of Latter-day Saints by three former members who alleged they were misled over the years by church leaders into participating in the faith as tithe-paying members.

Almost seven years later, the U.S. Supreme Court has declined a last-ditch petition for review in the case without comment, closing off a final legal avenue for plaintiffs Laura Gaddy, Lyle Small and Leanne Harris.

The high court’s refusal also marked yet another rejection in recent fraud suits involving tithing filed against the church that have hinged partly on a whistleblower’s explosive revelations in late 2019 regarding the Utah-based religion’s finances and immense wealth.

Church attorneys argued in several court venues that the Gaddy case and two others brought by current and former Latter-day Saints alleging fraud over tithing threatened to violate First Amendment protections — under what is known as the “church autonomy doctrine” — had they been allowed to proceed.

But, according to the plaintiffs’ attorney in what’s called the Gaddy case, legal findings in that regard will likely face future challenges.

“Although Gaddy involved allegations of criminal fraud,” said Salt Lake City lawyer Kay Burningham, “the broader question of whether the church autonomy doctrine can shield religious organizations from liability for criminal conduct remains unresolved and will likely continue to be tested in future cases.”

Another high-profile tithing fraud case against the faith — brought in 2021 by wealthy Utahn James Huntsman — was rejected by the 9th U.S. Circuit Court of Appeals in January 2025. Appellate judges in that lawsuit found that no “reasonable juror” could conclude the church committed fraud regarding its $1.4 billion investment toward the City Creek Center mall in downtown Salt Lake City, as Huntsman had alleged.

A third case, meanwhile, a would-be class-action lawsuit — brought in 2024 by nine current and former Latter-day Saints in six states over the church’s tithing practices — was thrown out of U.S. District Court in Utah last April, largely on technical grounds unrelated to church autonomy.

The judge in that case, Robert Shelby, dismissed the suit, saying it was incompletely argued and had been filed too long after the 2019 whistleblower’s expose on church finances to be legally valid.

That ruling remains on appeal before the Denver-based 10th U.S. Circuit Court of Appeals.

On behalf of Gaddy and other plaintiffs, Burningham argued in the petition for Supreme Court review that an August ruling by the 10th Circuit incorrectly concluded that delving into whether Latter-day Saint leaders intentionally deceived members on certain facts in church history would have forced the courts to decide matters of faith.

Burningham argued that several alleged church deceptions involved withholding information through the years regarding the manner of church founder Joseph Smith’s reported translation of the Book of Mormon, the faith signature scripture; details on his translation of the Book of Abraham, another canonical text; and Smith’s own personal history of polygamy.

Concealing certain historical facts, she said, was a key element in committing what amounted to mail and wire fraud, under federal racketeering laws.

But after several rejections by Shelby, the Gaddy case landed on appeal before the 10th Circuit, where judges there found that to review those historical claims would have “improperly” required them to decide “the truth or falsity of religious belief.”

Though U.S. Supreme Court Justice Neil Gorsuch last December allowed Gaddy and her co-plaintiffs additional time to prepare their request for review, the court declined on March 2 to grant the petition.

With the 10th Circuit finding effectively upheld and the high court’s refusal to review it, Burningham said, “the limits of the church autonomy doctrine will surely be tested again.”

Note to readers • This story has been updated to include the potential class-action case still on appeal before the federal court in Denver.