Syring v. Archdiocese of Omaha, 9 N.W.3d 445

Andrew J. Syring, a Catholic priest, sued the Archdiocese of Omaha after being named on a public list of clergy with allegations of sexual misconduct with minors and following a negative reference during a chaplaincy inquiry.
Syring served in various capacities within the Archdiocese between 2011 and 2018. He was removed from ministry in 2018, though previous investigations into an allegation did not find wrongdoing.
On November 30, 2018, the Archdiocese published a list naming Syring on its website; the list aimed for victim outreach and transparency.
The list was updated periodically, without changes to Syring's entry, and referenced in a phone call between Archdiocesan officials and a Catholic hospital regarding Syring's employment prospects in 2020.
Syring sued in October 2020 alleging defamation, tortious interference, slander per se, breach of fiduciary duty, and intentional infliction of emotional distress.
The district court dismissed some claims as time-barred and others under the ministerial exception and for failure to state a claim; the Supreme Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the libel claim timely under the statute of limitations?	Updates and references to the list created republications and new limitations periods	Single publication rule applied; no valid republications	Claims barred; original 2018 publication triggered the deadline
Did the list update or phone conversation create republication?	Both constituted republications of defamatory material	Neither update nor reference reached new audiences or repeated the defamatory content	No republication occurred under Nebraska law
Was the Archdiocese liable for intentional infliction of emotional distress?	Extreme and outrageous conduct in list/phone call	Conduct was not sufficiently outrageous; no medical evidence	Conduct did not meet the threshold for outrage as a matter of law
Did the ministerial exception/abstention doctrine bar claims?	Claims related to employment and reputational harm, not church doctrine	Claims implicated internal church governance and ministerial roles	Doctrine barred court involvement in church-minister employment matters

Timothy L. Ashford, PC LLO v. Roses, 313 Neb. 302 (Neb. 2023) (single publication rule applies to internet defamation; triggers limitations period at initial posting)
Hosanna-Tabor Evangelical Lutheran Church and School v. EEOC, 565 U.S. 171 (2012) (ministerial exception bars employment discrimination suits against churches over ministerial employment)
Watson v. Jones, 80 U.S. (13 Wall.) 679 (1871) (courts abstain from deciding issues strictly ecclesiastical in nature)
Serbian Orthodox Diocese v. Milivojevich, 426 U.S. 696 (1976) (ecclesiastical decisions by church tribunals are binding on civil courts)