A former principal of St. Joseph’s Catholic School in Des Moines will not get a new trial in her unsuccessful civil action against the Catholic Diocese of Des Moines, St. Joseph’s Church, and the pastor who supervised her, for fraud and defamation by all defendants, and breach of contract against the pastor, Father Joseph Pins, the Iowa Supreme Court held in a ruling handed down April 14. While the decision turned on unique facts of this case, the Court suggested it may be open to applying a “ministerial exception” to some civil claims against religious officials.
The breach-of-contract claim was dismissed on summary judgment by the Polk County District Court, along with the fraud claim, which Konchar did not challenge in her appeal. A jury ruled in the defendants’ favor on the defamation claims.
In unanimously affirming the District Court, the Supreme Court in an opinion written by Justice David May disagreed with Konchar on four issues raised on appeal. Justice Thomas Waterman wrote a separate concurring opinion, joined by Justice Matthew McDermott, in which he urged the Court to adopt a ministerial exception in such cases.
Konchar’s defamation claim triggered an analysis by the District Court regarding whether such claims could even be asserted against a Catholic priest. Konchar alleged she was defamed in an email from Father Pins to the school and parish community that said, among other things, that he had consulted with two prior pastors. Konchar argued that this statement implied the prior pastors had approved of Konchar’s firing in 2018 even though the prior pastors testified they were not consulted in 2018. In fact, Father Pins did consult the prior pastors in 2017.
“So the ‘two pastors’ statement was defamatory, Konchar believes, because it created the false appearance that Father Pins had valid reasons to fire her when — in fact — he had no valid reasons at all,” May wrote. “Instead, Konchar believes, Father Pins simply didn’t like her.”
The District Court concluded that for it to inquire into the question of whether a Catholic priest was justified in deciding that Konchar should no longer serve as the school principal would run afoul of the Free Exercise Clause of the First Amendment.
The Supreme Court said “we presume without deciding” that the District Court was correct on its interpretation of the Free Exercise Clause. Instead, the Court resolved Konchar’s appeal of the disposition of her defamation claim on the basis that the statement of which she complained was substantially true, and therefore entitled to First Amendment protection on that basis.
Justices Waterman and McDermott would have gone further on the Free Exercise Clause point, however, saying in the concurring opinion that while the majority opinion “leaves the door open” to application of a ministerial exception, they would have applied it in this case.
Waterman wrote that Konchar was a “minister within the meaning of the ministerial exception,” and the majority opinion recognized Konchar’s role as a spiritual leader running the school as a faith community.
“The ministerial exception better protects the autonomy of religious organizations guaranteed under the First Amendment to choose who ministers their faith and spares churches, dioceses, priests, and bishops the entanglement with costly civil litigation this case exemplifies,” Waterman wrote. “The extensive discovery, depositions, and trial spanning two weeks that these church defendants endured could have been avoided by a prompt dispositive motion under the ministerial exception long recognized by the United States Supreme Court, federal circuit courts, and other state courts.”
Although the Iowa Supreme Court has not formally applied the ministerial exception, it has applied the “ecclesiastical abstention doctrine,” under which courts may not determine the correctness of interpretation of canonical text or decisions relating to governing of a religious group.
“In my view, the ecclesiastical abstention doctrine inadequately protects the religious freedom of our churches and parochial schools,” Waterman wrote. “Church leaders should be able to decide who ministers to their faithful and who runs their religious schools without state interference or entanglement in our court system.”
[Disclosure: Nyemaster Goode attorneys Brianna L. Long, Frank Harty, and Haley Hermanson represented the defendant-appellees in this case.]
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