A Michigan appellate court in Howard v. Family Independence Agency has ruled that a state agency did not violate a social worker's First Amendment rights when it fired her for trying to perform an exorcism instead of calling 911 after a client had a seizure. While visiting a client, the client had a seizure, which Michelle Howard, a religious woman, decided was "demonic in nature." She prayed over the client and anointed her with water. The court ruled that she "was not terminated for merely praying at the office," but for violating agency rules.