• A New Jersey appeals court ruled that it had no authority to resolve a lawsuit brought by a priest against his diocese. A Catholic priest was arrested and charged with several sexual offenses involving a minor. Two days later, he was suspended from all priestly functions by his bishop. The priest later sued his bishop and diocese, claiming that the bishop had breached a promise to pay for all legal fees incurred in his defense. He sought $2.5 million in damages. A state appeals court ruled that it had no authority to resolve such a dispute. It acknowledged that “temporal matters of a church affecting civil, contract or property rights may be resolved in civil courts. Thus, secular courts may decide civil disputes between a religious body and its members or its clergy if those disputes involve purely secular issues and can be resolved without entanglement with matters of faith, discipline or doctrine.” The priest argued that this was such a case, since the court need only apply neutral principles of contract law to determine whether or not the bishop made a commitment (to pay legal fees) that he did not honor. The court rejected the priest’s assessment of the case, noting that it “ignores the relationship between the parties.” It observed:
[The priest] relies both on [the bishop’s] verbal promise of support and the church’s preexisting similar duty. In order to reach the contention that defendants have not honored these obligations, a civil court would necessarily inquire into the nature (religious or secular) of these alleged obligations. This inquiry would, of course, involve a searching an detailed exploration of the doctrine and practice of the Roman Catholic Church in order to determine the existence of such obligations. Civil courts are enjoined from such inquiry by the first amendment …. Accordingly, a determination of [the priest’s] claims would involve more than simply the secular questions of whether such promises were made and subsequently dishonored.
Further, whether or not the bishop had the authority to bind the diocese by his alleged promises is “an ecclesiastical matter, requiring inquiry into the structure of the Roman Catholic Church regarding the relationship between a bishop and his diocese. An agency relationship between a bishop and his diocese may only be determined by reference to church law.”
In summary, the priest’s claims “are replete with ecclesiastical issues, the resolution of which require impermissible court inquiry into the doctrine and practices of the Roman Catholic Church. These entanglements between religious and secular issues compel this court to refrain from exercising jurisdiction over this matter.” What is the significance of this ruling? Consider the following two points. First, it illustrates the reluctance of the civil courts to become involved in any dispute between clergy and their church or ecclesiastical superiors. While the courts often say that they will resolve purely “secular” church disputes involving application of neutral legal principles, this case demonstrates that “purely secular disputes” are rare in clergy-church controversies. Disciplined or dismissed clergy cannot invoke the assistance of the civil courts merely be asserting “secular” grounds for relief. Second, and just as importantly, the court concluded that the priest’s allegations of an agency relationship between the bishop and diocese were an ecclesiastical matter beyond the ability of the civil courts to resolve. This is a significant conclusion that will be useful to denominational offices that are sued as a result of the activities of affiliated churches and clergy. This case suggests that any allegation of liability based on a “agency relationship” between a denominational office and an affiliated church or minister is an ecclesiastical matter that can be resolved only “by reference to church law.” Accordingly, the civil courts are without legal authority to resolve such claims. McElroy v. Guilfoyle, 589 A.2d 1082 (N.J. Super. 1990).
See Also: Termination
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