Massive and un-restrained title change was necessary

77. In Wollersheim v. Church of Scientology of California (the "mother church" of the Churches of Scientology at the time the suit was filed), the California Appeal Court ruled, in a decision upheld by the US Supreme Court: "Wollersheim was compelled to abandon his wife and his family through the policy of disconnect. When his mental illness reached such a level he actively planned his suicide, he was forbidden to seek professional help. Finally, when Wollersheim was able to leave the Church, it subjected him to financial ruin through its policy of 'fair game'." (JCA-147, pp.A-7, 15 & 16). At appeal, Scientology asserted that "fair game" was a "core practice of Scientology", and therefore protected as "religious expression". This position was also made on behalf of Scientology in the case against Gerald Armstrong, in 1984, by religious expert Dr. Frank Flinn (JCA-45).

JCA-45. Frank K. Flinn testimony in Church of Scientology of California, 1984, vol.23, pp.4032-4160.

JCA-147. Wollersheim v. Church of Scientology of California, Court of Appeal of the State of California, civ.no.B023193, 18 July 1989 (upheld by the U,S. Supreme Court, 7 March 1994).