McElroy v. GuilfoyleMcElroy v. Guilfoyle
- Reporters:
- ,
- Before:
- Drozdowski
This is defendants’ motion to dismiss the complaint under
Defendants move to strike arguing that civil courts lаck subject matter jurisdiction over plaintiff‘s claims. Specifically defendants contend that plaintiff‘s claims are barred from civil court resolution by the First Amendment Free Exercise and Establishment Clauses since the issues presented require impermissible court inquiry into church doctrine and practice.
I.
This case introduces novel questions concerning the jurisdiction of secular courts over disputes between a church and its clergy members. For the reasons set forth below, I find that this court lacks jurisdiction over plaintiff‘s claims.
On March 9, 1985, plaintiff was ordained as a Roman Catholic priest and assigned to work as an associate pastor at St. Francis de Sales church in Barrington. On May 11, 1988, plaintiff was arrеsted and charged with several sexual offenses involving a minor. That same day, defendant Bishop Guilfoyle restricted plaintiff from any further exercise of his priestly ministry. Two days later, Guilfoyle suspended plaintiff from all priestly functions. Plaintiff received his employment benefits for the rest of the month but further payments were
On May 8, 1990, plaintiff filed his complaint against defendants George Guilfoyle, James McHugh and the Dioсese of Camden. The vagueness of plaintiff‘s claims necessitated limited discovery in order to clarify the gravamen of the complaint. Plaintiff‘s allegations are now clear. Plaintiff contends that Guilfoyle, with the authority to bind the Diocese, promised to handle plaintiff‘s legal affairs, including the payment of plaintiff‘s legal fees, involved in plaintiff‘s defense of the criminal charges. Plaintiff alleges that defendants have failed to honor this obligation and demands compensatory and punitive damages of $2,500,000.
Guilfoyle, in his certification, states that he had promised, on behalf of the Diocese, to pay plaintiff‘s legal fees in defense of a prior, unrelated theft charge and that the Diocese did, in fact, loan plaintiff the money to defend the theft charge. Guilfoyle denies having made any representations concerning the sexual offenses and, indeed, states that such promises would have been unauthorized without the consent of the diocesan finance council.
II.
Generally, civil courts have no jurisdiction over, and nо concern with, spiritual matters and the administration of church affairs that do not affect the civil or property rights of individuals. Chavis v. Rowe, 93 N.J. 103, 109, 459 A.2d 674 (1983). More specifically, the relationship between a priest and his diocese is not to be interfered with by civil courts, thus permitting priests to be selected, ordained, disciplined or discharged for reasons which the church deems proper. Minker v. Baltimore Annual Conference, 894 F.2d 1354, 1357 (D.C. Cir.1990).
However, 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 аnd 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. In such cases, courts are to apply neutral principles of law to the facts presented. Welter v. Seton Hall University, 243 N.J. Super. 263, 275, 579 A.2d 332 (App.Div. 1990).
Here, plaintiff argues that this court should apply neutral principles of contract law in dеtermining whether defendants failed to honor their obligations. Under this approach the court‘s inquiry would be limited to the purely secular issues of whether defendants made and subsequеntly dishonored certain promises concerning the payment of plaintiff‘s legal fees.
However, plaintiff‘s position ignores both the relationship between the partiеs and the nature of the alleged conduct underlying plaintiff‘s complaint. Defendants’ purported obligation to support plaintiff‘s defense of a criminal action is intertwined with, and dependent upon, plaintiff‘s tenure as a priest. The Code of Canon Law of the Roman Catholic Church details the reciprocal duties and obligations among сlergy members. The code also sets forth the appropriate sanctions for failure to honor these obligations. In short, the Code of Canon Law governs the relatiоnship between clergy members, lending that relationship an ecclesiastical quality which permeates this action.
New Jersey courts have consistently followed the guidance of the United States Supreme Court in holding that secular courts may not interfere with a church‘s religious determinations concerning questions of discipline, faith or ecсlesiastical law. Welter v. Seton Hall University, supra, 243 N.J. Super. at 273,
While plaintiff urges that this is a secular matter requiring the simple application of common law сontract principles, plaintiff has not clearly delineated how his claims are divorced from ecclesiastical issues. In describing the gravamen of his complaint, рlaintiff relies both on Guilfoyle‘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 and detailеd 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 Establishment and Free Exercise Clauses. Presbyterian Church v. Hull Memorial Presbyterian Church, 393 U.S. 440, 449, 89 S.Ct. 601, 606, 21 L.Ed.2d 658 (1969).
Accordingly, a determination of plaintiff‘s claims would involve more than simply the secular questions of whether such promises were made and subsequently dishonored. Rather, “plaintiff‘s complaint links the circumstances of his contractual rights and alleged breaches to his ... divestment of ecclеsiastical endorsement.” United Methodist Church v. White, 571 A.2d 790, 796 (D.C.App. 1990). The resolution of such disputes is properly for church officials. Ibid.
Moreover, assuming that Guilfoyle‘s promise of support was completely divоrced from religious considerations, whether Guilfoyle had the authority to bind the other defendants by such promises remains 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. See Minker v. Baltimore Annual Conference, supra, 894 F.2d at 1356 (A determination of “whose voice speaks for the church is per se a religious matter.“).
In sum, plaintiff‘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 jurisdictiоn over this matter.
The court‘s ruling does not leave plaintiff remediless. Plaintiff may pursue his claims administratively to the Congregation for the Clergy, whose decision is subject to review by thе Apostolic Signatura, the church‘s supreme court. Plaintiff may also pursue his claims judicially to the Tribunal of the Diocese of Camden. Review of the tribunal‘s decision is through the Mеtropolitan Tribunal of the Archdiocese of Newark, then to the Rota (the church‘s intermediate appellate court) and then to the Apostolic Signatura. Both оf these administrative and judicial processes afford a successful plaintiff the remedies sought in this action.1 Plaintiff‘s pursuit of these remedies is not foreclosed by this ruling. Motion granted.