Priest's Embezzlement Conviction Not Barred By First Amendment

In Rodis v. Attorney General of Virginia, 2012 U.S. Dist. LEXIS 42650 (WD VA, March 28, 2012), a Virginia federal district court held that the 1st Amendment does not preclude civil courts from convicting a Catholic priest of embezzlement of funds contributed by parishioners.  Rejecting Rodney Rodis' petition for habeas corpus, the court held:  "Petitioner's criminal acts, even if performed under the guise of ecclesiastical duties, are not shielded by the First Amendment because petitioner's prosecution did not relate to any ecclesiastical dispute, faith, or doctrine."