Suit Says Chicago Schools Program Promoted Hindu Beliefs

Organizations comprised of parents, students and churches this week filed suit in an Illinois federal district court challenging on Establishment Clause and free exercise grounds the "Quiet Time" program that has been implemented in a number of Chicago public schools. the complaint (full text) in Separation of Hinduism From Our Schools v/ Chicago Public Schools, (ND IL, filed 8/3/2020), alleges in part:

3. Although all named Defendants have made statements to the contrary, the “Quiet Time” program is based in Hindu beliefs and the practice of “Transcendental Meditation” is fundamentally religious in nature.

4. Plaintiffs’ rights under the First Amendment were violated when Defendants created environments within public schools where Hindu beliefs and the practice of “Transcendental Meditation” were being endorsed and students were coerced to engage in religious practices against their wills.

Christian News reports on the lawsuit.

New York Child Victims Act Filing Window Is Extended

Yesterday New York Governor Andrew Cuomo signed into law S7082 (full text) which extends the window for Child Victims Act lawsuits until August 14, 2021. (Press release). Originally, the window was for a one-year period ending this month. CNA, reporting on the new legislation, says that the change in the law was motivated by concern that the Covid pandemic has deterred many victims from coming forward in time to meet the prior deadline.

Anti-Kapparot Group Renews Attempt To Get NYC Police Enforcement of Health Code

As previously reported, in 2018 New York's highest court refused a writ of mandamus to require enforcement of public health and animal cruelty laws against the Jewish pre-Yom Kippur religious practice of kaporos using live chickens. The court held that mandamus cannot be used to order discretionary enforcement action.  Now a motion to renew the request for a mandamus petition has been filed, alleging that the COVID-19 pandemic has revealed new evidence relevant to the claim. In Alliance to End Chickens as Koporos v. New York City Police Department, (NY Ct. Sup. Ct.) a motion and affidavit (full text) filed 7/6/2020, focuses in large part on the animal-to-human spread of COVID-19, saying in part:

99. In light of the health, economic, and financial devastation caused [by] Covid-19, in light of how this pandemic [has] caused our lives to come to a grinding halt, in light of the hundreds of thousands of lives lost worldwide, and in light of the fact that Covid-19 originated from a live animal wet market, we cannot allow our police department to pick and choose what lows to enforce when it comes to the health code. Too much is at stake, which we all so painfully are currently aware of.

JTA reports on these developments. Attorney for plaintiffs issued a press release on the filing.

Attack On Connecticut COVID-19 Orders Rejected

In Murphy v. Lamont, (D CT, Aug. 3, 2020), a Connecticut federal district court rejected a wide-ranging constitutional attack, including 1st Amendment challenges, on the COVID-19 orders of Connecticut Governor Ned Lamont. The court found that plaintiffs lack standing, saying in part:

... Barnes asserts that he is “impeded from attending church.”... However, because no Executive Order prohibits religious worship, Barnes cannot show that the conduct he wishes to engage is “proscribed by statute.” ... Furthermore, Barnes alleges no facts as to his intention to attend religious services or any specific occurrence where he was prevented from doing so.

Murphy also asserts an injury to his religious liberty, along with his freedom of association. He alleges that, “[b]efore the illegal lock down orders, my family participated in a homeschooling group, in which we met in a church. We have not met since this lock down.”... Like Barnes’ allegations, these allegations are too vague to establish an injury-in-fact.

The court also found that plaintiffs were unlikely to succeed on the merits, saying in part:

Executive Order 7TT limits attendance of places of worship to 25% of building capacity or a maximum of 100 attendees, whichever is fewer.... In South Bay United Pentecostal Church, 140 S. Ct. at 1613, the Chief Justice, in his concurrence in the judgment denying a temporary injunction, found that those same restrictions (in California) did not violate the Free Exercise Clause. The court reaches the same conclusion here. The challenged Executive Orders are plainly neutral, and plaintiffs have not proffered any evidence to suggest that the Governor has any animus towards religious organizations. Indeed, more severe restrictions apply to secular gatherings.

Recent Articles of Interest

From SSRN:

• John Witte, Historical Foundations and Enduring Fundamentals of American Religious Freedom, (Journal of the Society of Christian Ethics 33 (2020): 156-167).
• John Witte, The Metaphorical Bridge between Law and Religion, (Pepperdine Law Review, Vol. 47, No. 2, 2020).
• John Witte, Response to Reviewers of John Witte, Jr., Church, State, and Family: Reconciling Traditional Teachings and Modern Liberties, (Journal of Law and Religion 34 (2019): 520-528).
• John Witte & Justin Latterell, Between Martin Luther and Martin Luther King: James Pennington's Struggle for 'Sacred Human Rights' Against Slavery, (Yale Journal of Law and the Humanities, Vol. 31, No. 1, 2020).
• Jodok Troy, Legitimacy in the ‘Secular Church’ of the United Nations, (International Relations, 2020).
• John Witte, 'Afterword,' to Russell Sandberg, ed., Leading Works in Law and Religion, (London: Routledge, 2019), 197-205).
• Frank Cullen, et. al., Catholics and Capital Punishment: Do Pope Francis's Teachings Matter in Policy Preferences?, (July 5, 2020).
• Michael J. Higdon, (In)Formal Marriage Equality, (July 19, 2020).
• Alan E. Garfield, Safe Zone or Battle Zone? Free Speech on the Campus Quad, (Delaware Lawyer - Fall 2019).
• Michael John Perry, The Morality of Human Rights, (Human Rights Quarterly 42 (2020) 434–478).

From SSRN (Non-U.S. Law):

• Krzysztof Gruszczynski, Jewish Restitution Claims Against Poland – Legal Analysis (July 1, 2020).
• Riya Puniyani, Uniform Civil Code and Conflicts of Personal Laws, (July 4, 2020).
• Fajri Muhammadin, The United Nations 'Beirut Declaration and its 18 Commitments on Faith for Rights': A Critique From An Islamic Perspective, IIUM Law Journal, Vol 28 No. 1, 2020.
• Rafi Nets-Zehngut, The Israeli-Jewish Collective Memory of the Israeli-Arab/Palestinian Conflict: A Suggested Model Verified by Survey Findings, (July 1, 2018).

From SmartCILP:

• Mark Strasser, Yoder's Legacy, 47 Hofstra Law Review 1335-1358 (2019).
• Skylar Reese Croy, In God We Trust (Unless We Change Our Mind): How State of Mind Relates to Religious Arbitration, 20 Pepperdine Dispute Resolution Law Journal 120-147 (2020).
• Benjamin W. Akins, A Broken Vesper: Questioning the Relevancy and Workability of the Church Audit Procedures Act, 44 Seton Hall Legislative Journal 1-38 (2020).

Limits On Street Preacher At Farmers Market Are Upheld

In Denton v. City of El Paso, 2020 U.S. Dist. LEXIS 135896 (WD TX, July 28, 2020), a Texas federal district court rejected free speech, free exercise and other challenges to a policy that prevents plaintiff, a street preacher, from proselytizing at the El Paso Art and Farmers Market. The city bars fundraising, political campaigning or religious proselytizing at the event. It also requires non-profits to distribute information only from designated booth space and bars organizations from approaching or shouting to those passing by.

The court said in part:

[C]onsidering the evidence in the record thus far, Plaintiff has not carried his burden to demonstrate a clear likelihood that the City's policy is content based. Instead, the evidence strongly suggests that the policy is content neutral.

...Because the City seeks to preserve the Market as a space for its visitors to converse with each other and local artisans and enjoy buskers' performances, it has a substantial interest in eliminating disruptive noise....

Moreover, the City also asserts a related economic interest in promoting vendors' ability to sell their wares without "having to shout over someone"...

Satanic Temple Has Promissory Estoppel Claim After Its Permit To Erect Memorial Was Voided

In The Satanic Temple v. City of Belle Plaine, Minnesota, (D MN, July 31, 2020), a Minnesota federal district court dismissed free exercise, free speech and equal protection claims by the Satanic Temple which objected to the city's Resolution 17-090 which rescinded a prior resolution that created a limited public forum in Veterans Memorial Park. The earlier resolution allowed individuals and organizations to erect and maintain privately owned displays to honor local veterans and veterans' organizations. The Satanic Temple had received a permit to erect a display, and spent substantial amounts for its design and construction, before the rescission. It argues that the rescission came about because of the controversial nature of its display.  The court said in part:

[A]lthough TST identifies the core tenants of its religion, TST fails to explain or allege facts that identify any central tenet of its religious beliefs that TST cannot exercise because of Resolution 17-090. Second, TST alleges no facts demonstrating that Resolution 17-090 prevents TST from expressing adherence to its faith. And third, TST fails to allege whether and how any activity that Resolution 17-090 prohibits is fundamental to TST’s religion.

The court however allowed Satanic Temple to move ahead with its promissory estoppel claim, saying in part:

TST sufficiently alleges that Belle Plaine should have reasonably expected that TST would expend time and resources to construct a display after receiving approval and that TST in fact expended such time and resources.

Finally, TST alleges sufficient facts that enforcement of Belle Plaine’s promise may be necessary to avoid injustice.

11th Circuit: Shame To Muslim Family From Assault Allegations Allows Woman To Proceed As Jane Doe

In Doe v. Neversome, (11 Cir., July 30, 2020), the U.S. 11th Circuit Court of Appeals held that that a Florida federal district court abused its discretion when it refused to allow a plaintiff in a sexual assault and battery action against a musical celebrity. The court said in part:

Here Ms. Doe ... asserts that because she is from a “devout Muslim family,” the “very nature of her allegations would be sufficient to bring harm to [herself] and shame to her family under the cultural/religious traditions that her family practices.”... The district court erred by treating Ms. Doe’s motion as merely alleging personal embarrassment, without accounting for what she actually alleged or considering our social stigma cases.

We also note that, under our precedent, the district court may have too easily discounted evidence that Ms. Doe would be subject to threats and harassment if she were required to proceed under her real name.

[Thanks to Eugene Volokh via Religionlaw for the lead.]

American On Trial For Blasphemy In Pakistan Is Assassinated In Courtroom

A press statement from the State Department yesterday reports on the killing of an American citizen, Tahir Naseem, inside a court room in Pakistan where he was on trial for blasphemy:

Mr. Naseem had been lured to Pakistan from his home in Illinois by individuals who then used Pakistan’s blasphemy laws to entrap him.  The U.S. Government has been providing consular assistance to Mr. Naseem and his family since his detention in 2018 and has called the attention of senior Pakistani officials to his case to prevent the type of shameful tragedy that eventually occurred.

The State Department called for the reform of Pakistan's blasphemy laws.  Radio Free Europe adds details:

It was not clear how the suspect, identified as Khalid Khan, managed to gain access to the courtroom.

He told police the prophet Muhammad had ordered him to kill Nasim because he had belonged to the Ahmadi faith....

According to BBC News:

Mr Naseem was first accused of blasphemy by Awais Malik, a madrassa student from Peshawar. Mr Naseem had struck up an online conversation with him whilst living in the United States.

Mr Malik told the BBC he had then met Mr Naseem in a shopping mall in Peshawar to discuss his views on religion, after which he filed a case against him with the police....

Mr Naseem was born into the persecuted Ahmadi sect, according to a spokesman for the community. But he added that he had left the sect and claimed to be a prophet himself.

The community leader suggested Mr Naseem had been mentally ill - he had uploaded videos to YouTube claiming to be a messiah.

Canadian Court Says Catholic Archdiocese Is Vicariously Liable For Sexual Abuse At Orphanage

In John Doe v. Roman Catholic Episcopal Corporation of St. John's, (Newfoundland & Labrador Ct. App., July 28, 2020), the Court of Appeal in the Canadian province of Newfoundland, in a 136-page opinion, held that the Catholic Archdiocese is vicariously liable for sexual abuse suffered by the four plaintiffs.  Five members of the Christian Brothers abused plaintiffs in the 1950's when they were living at the Mount Cashel Orphanage. The court said in part:

In our view, the total relationship between the Brothers at Mount Cashel and the Archdiocese shows that the Brothers were working on the account of the Archdiocese’s social and religious mandate. Their relationship was sufficiently close, and the connection between the Brothers’ assigned tasks and their wrongdoing was sufficiently close, to justify the imposition of vicarious liability on the Archdiocese. Doing so in the circumstances of this case upholds the policy objectives of the doctrine. 

The court held however that the Archdiocese is not liable for a chaplain's failure to act after he learned of the abuse, saying in part:

As Monsignor Ryan was not negligent and did not breach a fiduciary duty, there is no basis upon which the Archdiocese could be liable for his conduct.

Canadian Press reports on the decision.

Ministerial Exception Doctrine Leads To Dismissal of Music Director's Discrimination Suit

In Menard v. Archdiocese of Boston, (MA App., July 29. 2020), a Massachusetts state appellate court held that the ministerial exception doctrine requires dismissal of a sex and age discrimination suit against the the Archdiocese.  In the suit, a church's director of music ministries claimed that the church's pastor subjected her to harassment and that she was retaliated against when she notified the Archdiocese. The court said in part:

In this case, Menard's job duties place her squarely within the ministerial exception. As implied by her title, director of music ministries, Menard's role was a substantive one. She selected and played music at all parish events, taught and conducted multiple choirs, trained the church's cantors, and organized the cantors' schedule for Mass. Far more than the rote playing of an instrument, ... Menard's job required her to thoughtfully select the music for each event and train others to perform it. 

Suit Challenges North Carolina Opportunity Scholarship Program

Suit was filed in a North Carolina state trial court this week challenging North Carolina's Opportunity Scholarship Program.  The complaint (full text) in Kelly v. State of North Carolina, (NC Super. Ct., filed 7/27/2020), alleges that as implemented the Program violates various provisions of the North Carolina state Constitution. The complaint says in part:

2. The Program sends millions of taxpayer dollars to private schools without imposing any meaningful educational requirements. As implemented, many of the Program’s funds are directed to schools that divide communities on religious lines, disparage many North Carolinians’ faiths and identities, and coerce families into living under religious dictates.

3. The Program as implemented funds discrimination on the basis of religion. Families’ ability to participate in the Program is limited by their religious beliefs and their willingness to cede control of their faith to a religious school.

4. The Program as implemented funds schools that discriminate against students and parents based on who they love or the gender they know themselves to be, and against those with religious beliefs that do not condemn homosexuality, bisexuality, or gender non-conformity.

NCAE issued a press release announcing the filing of the lawsuit. AP reports on the lawsuit.

Hajj Begins Tomorrow-- Scaled Down In Response To Pandemic

The Hajj begins tomorrow in Saudi Arabia, in a scaled down fashion because of the COVID-19 pandemic.  AP and Andoula Agency both report on the event which will be limited to between 1,000 and 10,000 participants who are already living in Saudi Arabia. Normally the Hajj attracts 2.5 million pilgrims. According to AP:

This year, pilgrims must wear face masks and will only be able to drink holy water from the Zamzam well in Mecca that has been pre-packaged in plastic bottles. Pebbles for casting away evil that are usually picked up by pilgrims along hajj routes will be sterilized and bagged before being distributed to pilgrims.

Pilgrims are also bringing their own prayer rugs and will be required to pray at a distance from one another, rather than packed shoulder to shoulder.

Recent Articles of Interest

From SSRN:

• Myriam Caroline Hunter-Henin, Why Religious Freedom Matters for Democracy, (June 11, 2020).
• Carl H. Esbeck, The Free Exercise Clause, Its Original Public Meaning, and the Reconsideration of Employment Division of Oregon v. Smith, (University of Missouri School of Law Legal Studies Research Paper No. 2020-21 (2020)).
• Christoph Meyer, Non-Christians in the Normative Culture of the Catholic Church between Antiquity and the Modern Era: A Select Bibliography, (Max Planck Institute for European Legal History Research Paper Series No. 2020-15: subsidia et instrumenta (2020).
• S. Ernie Walton, The Fundamental Right to Homeschool: A Historical Response to Professor Bartholet, (Texas Review of Law & Politics, Forthcoming).
• Nelson Robert Lund, Unleashed and Unbound: Living Textualism in Bostock v. Clayton County, (Federalist Society Review, Forthcoming 2020).

From SSRN (Non-U.S. Law):

• Garima Tripathi, Legacy and Legality of Abortions in India and USA, (June 5, 2020).
• Liav Orgad, Forced to be Free: The Limits of European Tolerance, (Harvard Human Rights Journal, Vol. 34, 2020).
• Julie Fraser, Exploring Legal Compatibilities and Pursuing Cultural Legitimacy: Islamic Law and the International Criminal Court, (in Julie Fraser and Brianne McGonigle Leyh (eds.), Intersections of Law and Culture at the International Criminal Court (Edward Elgar 2020)).
• Barry Winston Bussey, Making Registered Charitable Status of Religious Organizations Subject to 'Charter Values', (in Bussey, B. W., The Status of Religion and the Public Benefit in Charity Law. London, UK: Anthem Press. (2020).)
• Samuel Singer, Trans Rights Are Not Just Human Rights: Legal Strategies for Trans Justice, (35:2 Canadian Journal of Law and Society (2020, Forthcoming)).
• Allah Ditta Qadri, The Tradition of Innovation in Islamic Civilization: An Exclusive Study of Early Ages of Islam, (Almilal Journal of Religion and Thought Pakistan, 2020).
• Sankar Varma, The Formation Behind the Creation of the ‘Other’ – Caste Casting, (June 25, 2020).
• Frederick Chikoti, Constitution (Amendment) Bill No. 10: A Fundamental Perspective, (June 29, 2020).

Supreme Court, 5-4, Refuses To Enjoin Pending Appeal Nevada Limits On Worship Services

By a 5-4 vote, the U.S. Supreme Court on Friday refused to grant an injunction pending appeal to a church that is challenging Nevada Governor Steve Sisolak's COVID-19 Order limiting worship services to no more than 50 people with social distancing. A Nevada federal district court upheld the Nevada Order. ( See prior posting). The 9th Circuit denied an emergency motion for injunctive relief pending appeal. In Calvary Chapel Dayton Valley v. Sisolak, (US Supreme Court, July 24, 2020), while the majority did not file an opinion explaining their vote, the four dissenting Justices did. Justice Alito filed a dissenting opinion, joined by Justices Thomas and Kavanaugh, finding free speech and free exercise violations, saying in part:

The Constitution guarantees the free exercise of religion. It says nothing about the freedom to play craps or blackjack, to feed tokens into a slot machine, or to engage in any other game of chance. But the Governor of Nevada apparently has different priorities. Claiming virtually unbounded power to restrict constitutional rights during the COVID–19 pandemic, he has issued a directive that severely limits attendance at religious services. A church, synagogue, or mosque, regardless of its size, may not admit more than 50 persons, but casinos and certain other favored facilities may admit 50% of their maximum occupancy—and in the case of gigantic Las Vegas casinos, this means that thousands of patrons are allowed.

That Nevada would discriminate in favor of the powerful gaming industry and its employees may not come as a surprise, but this Court’s willingness to allow such discrimination is disappointing.

Justice Gorsuch filed a brief dissent, saying in part:

The world we inhabit today, with a pandemic upon us, poses unusual challenges. But there is no world in which the Constitution permits Nevada to favor Caesars Palace over Calvary Chapel.

Justice Kavanaugh also filed a separate dissent, laying out a broad framework for approaching religion cases. He says in part:

The definitional battles over what constitutes favoritism, discrimination, equality, or neutrality can influence, if not decide, the outcomes of religion cases. But the parties to religion cases and the judges deciding those cases often do not share a common vocabulary or common background principles. And that disconnect can muddy the analysis, build resentment, and lead to litigants and judges talking past one another.

In my view, some of the confusion and disagreement can be averted by first identifying and distinguishing four categories of laws: (1) laws that expressly discriminate against religious organizations; (2) laws that expressly favor religious organizations; (3) laws that do not classify on the basis of religion but apply to secular and religious organizations alike; and (4) laws that expressly treat religious organizations equally to some secular organizations but better or worse than other secular organizations. As I will explain, this case involving Nevada’s reopening plan falls into the fourth category.

New Suit Charges Former Cardinal McCarrick With Sexual Abuse and Dioceses With Negligence

Suit was filed in a New Jersey state court this week against two New Jersey Catholic Dioceses, other Catholic entities, and former Catholic Cardinal Theodore McCarrick .  The complaint (full text) in JA/GG Doe 14 v. Diocese of Metuchen, (NJ Super, filed 7/21/2020), charges McCarrick with sexual battery and the Dioceses and schools with negligent training, supervision and retention. A news conference by the lawyers who filed the lawsuit described the suit as:

... [A] new lawsuit filed under the New Jersey Child Sexual Abuse Act (part of the New Jersey Victims’ Rights Bill), by a survivor who was sexually abused by infamous serial sexual predator and former Cardinal Theodore E. McCarrick as part of McCarrick’s sordid beach house child sex ring;

... Plaintiff, then a teenager, was groomed, manipulated and coerced by McCarrick into participating in McCarrick’s sex ring along with other kids;

... McCarrick orchestrated and directed the sexual abuse of the Plaintiff by three other priests named in the complaint.

Washington Post reports on the lawsuit.

Wedding Services Company Challenges Public Accommodation Non-Discrimination Ordinance

A Christian minister, Kristi Stokes, the owner of Covenant Weddings LLC, filed suit in an Ohio federal district court this week challenging the constitutionality of Cuyahoga County, Ohio's public accommodation ordinance (full text) which which makes it illegal for any public accommodation to

discriminate against, or treat differently any person except for reasons applicable alike to all persons regardless of race, color, religion, military status, national origin, disability, age, ancestry, sex, sexual orientation, or gender identity or expression...

The complaint (full text) in Covenant Weddings LLC v. Cuyahoga County, (ND OH, filed 7/22/2020) alleges in part:

The County ... cannot rescind religious liberty and free speech by relabelling them discrimination....

Through Covenant Weddings, Kristi personally officiates and writes custom homilies, vows, and prayers for weddings...

The Accommodations Clause forces Kristi to provide her wedding services for same-sex wedding ceremonies or for wedding ceremonies where a marrying individual identifies as the opposite sex and would require Kristi to proclaim messages and to participate in religious ceremonies that violate her religious beliefs, which she cannot do.... 

This undercuts Kristi’s message (expressed elsewhere in her social media accounts and wedding services) celebrating marriage between one man and one woman; harms Kristi’s reputation among her past and prospective clients; undermines her editorial control over what services she offers to the public; and adversely affects Kristi’s ability to share biblical truths about marriage with others....

ADF issued a press release announcing the filing of the lawsuit.

Suit Challenges South Carolina Grants To Private School Students

As reported by The Island Packet, a South Carolina state court judge in Adams v. State of South Carolina, (SC Com.Pl., July 21, 2020) has issued a temporary restraining order (full text) prohibiting the distribution of  Safe Access to Flexible Education (SAFE) Grants until a July 29 hearing in the case.  The grants are in the form of one-time tuition vouchers for low-income families sending their children to  private schools (including religious schools). They are funded through the federal CARES Act.  In a complaint (full text) filed July 21, a taxpayer contends that the grants violate the ban in the South Carolina constitution on the expenditure of public funds for the direct benefit of any religious or other private educational institution. The complaint alleges that the grants will give private school students some 13 times as much as the amount received per public school student under the CARES Act.

Texas AG Says Cities Cannot Restrict Reopening of Religious Private Schools

A July 17 press release from Texas Attorney General Ken Paxton reads in part:

Attorney General Ken Paxton today issued a guidance letter to religious private schools in Texas, informing them that local public health orders attempting to restrict their reopenings violate the United States and Texas Constitutions and the Texas Religious Freedom Restoration Act. Moreover, local orders seeking to restrict the reopening of religious private schools or institutions is inconsistent with Governor Abbott’s executive orders, and therefore, are invalid.

Here is the full text of the letter, which concludes:

Thus, as protected by the First Amendment and Texas law, religious private schools may continue to determine when it is safe for their communities to resume in-person instruction free from any government mandate or interference. Religious private schools therefore need not comply with local public health orders to the contrary.

Problem Meeting Parking Requirements Can Be RLUIPA "Substantial Burden"

In Immanuel Baptist Church v. City of Chicago, (ED IL, July 20, 2020), an Illinois federal district court held that plaintiff Church adequately pleaded that the city's parking regulations imposed a "substantial burden" under RLUIPA on its religious exercise. The court said in part:

Church was burdened by substantial expense, time and resources trying to comply with the City’s parking requirements. Under the original deal it had with the owner of the Property, the Church intended to purchase two buildings. Because of the City’s determination that the Church did not comply with its parking requirements, the Church was not able to close on the deal in 2016. Then when it was able to close on the deal two years later, the Church was only able to purchase one building. And during that delay, the Church spent money paying rent and used significant resources trying to negotiate with the City and identify potential parking solutions. Although the City finally exempted the Church from the parking requirement in 2019, that did not change the fact that the Church had spent significant time, money, and resources over those years, and lost the opportunity for ownership of one of the buildings. All of this was particularly difficult for the Church which has great needs and very limited resources....