A federal judge has permanently dismissed Southwestern Baptist Theological Seminary from the long-running defamation lawsuit filed by Jane Roe, while leaving the door open for a jury trial against former seminary President Paige Patterson in the summer 2026.
This lawsuit, originally filed in 2019, has become one of the most protracted legal battles in recent Southern Baptist history, keeping the details of Patterson’s controversial exit from Southwestern in the headlines seven years after his firing.
In a Dec. 1 opinion, U.S. District Judge Sean D. Jordan ruled that while the seminary is no longer liable, claims against Patterson regarding a controversial 2018 donor letter remain active. However, the court simultaneously granted Patterson a final opportunity to seek dismissal before facing a jury.
The ruling clarifies a chaotic and long-running legal battle for what once was the nation’s largest freestanding theological seminary and its former embattled president.
The legal path of the case has bounced between the 5th U.S. Circuit Court of Appeals and the Supreme Court of Texas.
Plaintiff Jane Roe — a former student who alleges she was sexually assaulted by another student in 2014 — argued recent appellate decisions had revived her claims against both Patterson and the seminary.
Judge Jordan disagreed, ruling the seminary cannot be held liable for the actions of employees who were working “against the interests” of the institution.
The court found that while seminary employees, including Patterson’s former Chief of Staff Scott Colter, may have participated in drafting the defamation, they did so to criticize the seminary’s decision to fire Patterson.
Because they were acting outside the scope of their employment, the seminary is not legally responsible for their conduct.
Because they were acting outside the scope of their employment, the seminary is not legally responsible for their conduct.
“All claims against SWBTS have been, and remain, dismissed,” Jordan wrote.
The case against Patterson now narrows to a single document: the so-called “Loveless Letter.”
Sent in June 2018 by donors Gary Loveless and Susan Oliver to the seminary’s board of trustees, the letter defended Patterson after his termination by Southwestern’s board of trustees.
The letter allegedly contained false claims that Roe had lied about her rape, engaged in consensual sexual acts in campus buildings and shared nude photos with her alleged attacker, who is now deceased.
Roe alleges Patterson, although he did not sign the letter, “supplied” the defamatory information through Colter, his close aide.
Earlier this year, the Texas Supreme Court clarified state law, ruling that a person can indeed be liable for defamation if they “supply” information to another knowing it will be published — only after inadvertently publicizing 10,000 pages of discovery material in the case last summer.
The high court noted that a plaintiff does not need to prove the defendant wrote the specific words, provided there is sufficient evidence they were the source of the claim.
Despite keeping Patterson in the lawsuit, Judge Jordan expressed skepticism about whether the evidence against him rises above “mere speculation.”
In a separate order issued Dec. 1, the court granted Patterson permission to file a new motion for summary judgment by Dec. 22.
Patterson’s attorneys are expected to argue that even under the new Texas Supreme Court standard, there is no concrete proof he was the source of the lies in the donor letter.
If Patterson fails to win this dismissal, the case will proceed to a jury.
The court’s new scheduling order sets a final pretrial conference for June 10, 2026, with jury selection and trial scheduled to begin June 15, 2026, at the federal courthouse in Plano.
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