Saying judges cannot become entangled in church administrative decisions, an appeals court Wednesday blocked a Catholic priest’s defamation lawsuit against the Diocese of Palm Beach.
The lawsuit, filed by priest John Gallagher, came after series of events that started with allegations in early 2015 that another priest at Holy Name of Jesus Catholic Church in West Palm Beach had shown child pornography to a 14-year-old boy. The other priest, Joseph Palimattom, was arrested, pleaded guilty and was ultimately deported to his native India, according to Wednesday’s ruling in the 4th District Court of Appeal.
After the incident involving the other priest, Gallagher was not offered the job of pastor of Holy Name and was reassigned to another parish, a transfer he did not accept. He alleged that the diocese tried to cover up the child-pornography incident and that he was reassigned for not going along, Wednesday’s ruling said. Gallagher, who is from Northern Ireland, also made accusations against the diocese during an interview on Irish radio.
In response, diocese officials made critical comments about Gallagher, who alleged that he had been defamed because of statements about him being a liar, unfit to be a priest and in need of professional help, Wednesday’s ruling said.
A circuit judge refused to dismiss the lawsuit, but the appeals court sided with the diocese, at least in part because the court said judges cannot get involved in church decisions about issues such as employment.
“Father Gallagher’s complaint that the diocese’s statements were false and resulted in actual damages cannot be decided on neutral principles,” said the ruling, written by Judge Robert Luck and joined by judges Barbara Lagoa and Edwin Scales. “These claims would entangle the courts in the diocese’s ministerial staffing decisions, the interpretation and application of canons and doctrines, and church discipline, which the civil courts must abstain from reviewing and deciding.”
The three judges serve in the neighboring 3rd District Court of Appeal, but the Florida Supreme Court directed that the case be handled by a panel from that court instead of the 4th District Court of Appeal, which typically decides issues from Palm Beach County.
The ruling focused heavily on a legal concept known as the “ecclesiastical abstention doctrine,” which prevents civil courts from getting involved in issues involving management of churches. While Gallagher alleged wrongdoing in his reassignment, the ruling said diocese officials had met with Hispanic church members who had been dissatisfied with how they were treated by Gallagher.
The court said it “must ask whether Father Gallagher’s defamation claim can be decided on neutral principles of secular law; or, is this a ministerial employment dispute that would require the courts to get excessively entangled in issues of internal church discipline, faith, and organization that are governed by ecclesiastical rule, custom, and law.”
“Determining the falsity of whether Father Gallagher was unfit to serve gets the court excessively entangled in Catholic Church doctrines and canonical law,” the ruling said, addressing one of Gallagher’s allegations. “The falsity question turns on whether Father Gallagher was doing what he was supposed to be doing as a priest and parochial administrator at Holy Name. In his interactions with parishioners, fellow priests, and the diocese hierarchy, was Father Gallagher following church canons and teachings? Father Gallagher says yes; the diocese says no.
“We do not need to answer the question because asking it requires us to determine the duties assigned to a priest that make him fit to serve, and whether Father Gallagher was qualified to do the job. A determination of a priest’s duties and whether he is qualified to serve are uniquely decisions of the diocese and would excessively entangle us in questions of religious administration and government, and the procedures and dictates of the Catholic faith.”
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