Suit Over Priest's Breach of Confessional Secrecy Is Dismissed

In Sonnier v. Roman Catholic Diocese of Lafayette, 2017 U.S. Dist. LEXIS 26498 (WD LA, Feb. 23, 2017), a Louisiana federal district court adopted a magistrate's recommendation (2017 U.S. Dist. LEXIS 27235, Jan. 18. 2017) and dismissed an action alleging invasion of privacy and defamation brought by a member of a Catholic church who claimed that a priest violated his 1st Amendment rights by disclosing plaintiff's use of the confessional to communicate with individuals involved in a civil litigation matter. The court concluded that the 1st Amendment does not apply because no state actor was involved in the conduct.  The court went on to hold that in addition:

Plaintiff's claims fall within the scope of internal religious affairs as they are predicated on: (1) the breach of the sacramental seal of confession, as defined by the Roman Catholic Church; and (2) Bishop Jarrell's failure to remedy the breach in accordance with church doctrine. In order to discern whether Plaintiff has asserted meritorious claims against Defendants, the Court would have to interpret church doctrine relating to the sacrament of confession and otherwise encroach upon the internal affairs of the Roman Catholic Church. Application of long-standing First Amendment jurisprudence, therefore, mandates that this Court refrain from considering Plaintiff's claims.