Friday, June 17, 2022

Ecclesiastical Abstention Doctrine Bars Mississippi Courts From Adjudicating Claims Of Fired Diocese Finance Officer

In Catholic Diocese of Jackson, Mississippi v. DeLange, (MS Sup. Ct., June 16, 2022), the Mississippi Supreme Court held that the ecclesiastical abstention doctrine prevents Mississippi courts from adjudicating wrongful termination, defamation and infliction of emotional distress claims brought by the former Finance officer of the diocese.  Plaintiff was given several reasons for his termination by the bishop. Under the Code of Canon Law, the Finance officer can be removed only for "grave cause." Plaintiff claimed that the reasons given for his termination were false. The court said in part:

 ... de Lange argues that his request merely asks a court to determine the truthfulness of the reasons given by the Diocese for his termination. De Lange insists that a civil court will not be required to interpret the Code of Canon Law. We disagree.

Even if the Diocese’s reasons were found to be based on falsehoods, and we are making no such determination, a reason existed for de Lange’s termination. That is, there was some reason for his termination, whether it is one of the reasons cited by the Diocese or, perhaps, it is simply the apparent incompatibility that existed between de Lange and Bishop Kopacz. Whatever that reason may be and regardless of the strength of that reason, the request that de Lange now makes ... would ultimately require judicial interpretation of what constitutes “grave cause” under the Code of Canon Law....  Such an interpretation is off limits for a civil court to make.