Saying judges cannot become entangled in church administrative decisions, a state appeals court Wednesday blocked a whistleblowing Catholic priest’s defamation lawsuit against the Diocese of Palm Beach.
The lawsuit, filed by the Rev. John Gallagher, came after a series of events starting with allegations in 2015 that another priest at Holy Name of Jesus Catholic Church in West Palm Beach showed child pornography to a 14-year-old boy. The other priest, the Rev. Joseph Palimattom, was arrested, pleaded guilty and was deported to his native India, the Fourth District Court of Appeal opinion said.
Afterward, Gallagher was not offered the job of pastor of Holy Name and was reassigned to another parish, a transfer he did not accept. He claimed the diocese tried to cover up the child-pornography incident and that he was reassigned in retaliation for not going along. Gallagher, who is from Northern Ireland, made accusations against the diocese during an interview on Irish radio.
In response, diocesan officials made critical comments about Gallagher, who alleged he had been defamed by being called a liar, unfit to be a priest and in need of professional help in social media, newspaper articles, letters to parishioners, website press statements and interal email.
Palm Beach Circuit Judge Meenu Sasser refused to dismiss the lawsuit, but the appellate panel court sided with the diocese under the ecclesiastical abstention doctrine, at least in part because the court said judges can’t 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,” the ruling said. “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.”
In an unusual direction from the Florida Supreme Court, the case was redirected from Fourth District judges in West Palm Beach to a panel of judges from the Third District Court of Appeal in Miami. Judge Robert Luck wrote the unanimous opinion, and Judges Barbara Lagoa and Edwin Scales concurred.
The ruling focused heavily on 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 diocesan officials had met with Hispanic church members who were 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.”
Jim Saunders reports for the News Service of Florida.