In Martins v. Romero, (ED MI, Aug. 21, 2026), a Michigan federal district court refused to dismiss a suit by a Catholic priest against a podcaster and a frequent guest on the podcast, alleging that their podcasts defamed him and cast his exorcism ministry in a false light by falsely claiming that Martins was not an exorcist. On one episode, defendant made the claim by reading only part of an email from Fr. Martins religious order, giving the false impression that Martins had not been authorized to perform exorcisms.
Defendants argue that the issue of whether Plaintiff is an exorcist raises a “substantial danger that the State will become entangled in essentially religious controversies....
Plaintiff contends, on the other hand, that this case does not involve church doctrine and merely involves false statements of fact, made with actual malice....
... [T]he court need only resolve whether Defendants’ statements that Plaintiff’s Order said he was not an exorcist were untrue and thus defamatory. Whether Fr. Martins is qualified under Catholic doctrine as an exorcist is irrelevant to this inquiry. Thus, the court finds that at this stage of the proceeding, the affirmative defense of the ecclesiastical [abstention] doctrine does not bar Plaintiff’s claims....
Defendants argue that they had no obligation to read a sentence in an email to which they objected. However, Defendants’ affirmative statements appear to have crossed the line between an opinion that Fr. Martins is not an exorcist to statements of fact that the email from his own Order says that he is not an exorcist. And according to the Complaint, such statements are demonstrably false based on the email itself, which does not say that Fr. Martins is not an exorcist.
For these reasons, the court concludes that the alleged defamatory statements at issue are not opinions protected by the First Amendment. Accordingly, dismissal on this basis is not appropriate....
(See prior related posting.)
[Thanks to Eugene Volokh via Religionlaw for the lead.]
