Fed Court - No Civil Claims For Slander In Catholic Church Annulment Cases And Other Confidential Church Proceedings

I am not sure what has got Volokh Conspiracy bothered in this very interesting case. See Free Exercise Clause Absolutely Bars Slander Claims Based on Statements in Confidential Church Proceedings.

I think the Judge got it right. I mean in the end one has to prove damage and what damage could be proven that is a purely civil matter?

Now what if this dealt with some Clergy misconduct and the clergyman sues for slander on the basis he lost his job? I have to read the whole opinion but this seems pretty narrow to me.