Roman Catholic Archdiocese of San Juan v. Acevedo Feliciano, 140 S. Ct. 696

In 1979 the Archdiocese created the Pension Plan for Employees of Catholic Schools Trust (the Trust) covering several Catholic academies in Puerto Rico.
In 2016 active and retired employees sued after the Trust allegedly terminated the pension plan, naming the Archdiocese, the Trust, three academies, the Superintendent, and the “Roman Catholic and Apostolic Church of Puerto Rico.”
The Puerto Rico Court of First Instance ordered the Church (as the only entity it found to have legal personality) to pay pensions and issued asset-seizure and deposit orders; the Court of Appeals and Puerto Rico Supreme Court issued conflicting rulings about which entities had legal personality.
The Puerto Rico Supreme Court held that the Catholic Church in Puerto Rico is a single civil-legal entity (so the named “Roman Catholic and Apostolic Church in Puerto Rico” alone could be ordered to pay) and reinstated the injunction.
After the Puerto Rico Supreme Court remanded, the Archdiocese removed the case to federal district court; the state trial court issued the payment/seizure orders while removal was pending and before the federal court remanded.
The U.S. Supreme Court vacated the Puerto Rico Supreme Court judgment and remanded, holding the state-court payment and seizure orders void because the state court lacked jurisdiction after removal; the Court did not decide the Free Exercise or religious-autonomy claims.

Issue	Plaintiff's Argument	Defendant's Argument	Held
1) State-court jurisdiction after removal	Plaintiffs treated state-court orders as valid and enforceable	Archdiocese argued removal divested state court of jurisdiction; orders issued after removal are void	Orders issued after removal were void; state court lacked jurisdiction until remand, so judgment vacated
2) Whether Puerto Rico Supreme Court properly treated the Catholic Church as a single legal person / religious-autonomy claim	Plaintiffs relied on civil-law recognition of Church personality and sought to hold Church liable	Archdiocese argued First Amendment (religious autonomy / Free Exercise) requires deference to Church’s view of its internal structure and separate diocesan legal personalities	Court did not reach Free Exercise or religious-autonomy issues (reserved for remand)
3) Effect of district court’s nunc pro tunc remand to retroactively restore state-court actions	Plaintiffs relied on the remand judgment’s retroactive effective date to validate state orders	Archdiocese argued nunc pro tunc cannot create events that did not occur; federal court only remanded later	The Court rejected the nunc pro tunc as a basis to validate state-court orders; state actions during federal jurisdiction remain void

Watson v. Jones, 80 U.S. 679 (1872) (courts must accept church judicatories’ final decisions on ecclesiastical questions)
Municipality of Ponce v. Roman Catholic Apostolic Church in Porto Rico, 210 U.S. 296 (1908) (treaty recognized Church’s juridical personality under the Treaty of Paris)
Kern v. Huidekoper, 103 U.S. 485 (1881) (state court loses jurisdiction after removal)
Steamship Co. v. Tugman, 106 U.S. 118 (1882) (orders entered after removal are coram non judice)
Cuebas y Arredondo v. Cuebas y Arredondo, 223 U.S. 376 (1912) (nunc pro tunc decrees presuppose an order actually allowed but not entered)
Missouri v. Jenkins, 495 U.S. 33 (1990) (nunc pro tunc reflects what already occurred; court cannot make record what did not happen)
Church of Lukumi Babalu Aye, Inc. v. Hialeah, 508 U.S. 520 (1993) (Free Exercise prohibits laws singling out a religion for discriminatory treatment)
Fowler v. Rhode Island, 345 U.S. 67 (1953) (Free Exercise protections in enforcement of general laws)
United States v. Gillespie, 666 F. Supp. 1137 (N.D. Ill. 1987) (criticizing misuse of nunc pro tunc to rewrite history)