The petitioner made claims against the respondent, the Roman Catholic Diocese of Dallas (“Diocese”), claiming that the Diocese mishandled his complaint that a priest had sexually abused him. The district court dismissed the case for lack of jurisdiction, citing the ecclesiastical-abstention doctrine. The Court of Appeals affirmed the district court’s judgment. The petitioner then petitioned the Texas Supreme Court.

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Disposition

In Doe v. Roman Catholic Diocese of Dall., No. 21-1050 (Tex. 2022), the Texas Supreme Court denied the petition for review.

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The ecclesiastical-abstention doctrine

Justice Lehrmann explained in her concurrence that the ecclesiastical-abstention doctrine means that courts may not adjudicate claims that ask courts to evaluate whether the church followed its own canonical rules and internal affairs policies. Justice Lehrmann noted that the petitioner did not assert claims of sexual abuse against the Diocese, nor did he claim that the Diocese negligently or intentionally allowed the accused priest to harm others. Rather, the petitioner’s claim was based on the allegation that the Diocese did not fulfill its alleged promise to follow the ecclesiastical processes described in its internal policy when it conducted its investigation into the petitioner’s allegations and secured the priest’s resignation (at 1). Because the petitioner's claims were based on the allegation that the Diocese did not fulfill its alleged promise to follow the ecclesiastical processes described in the policy, resolving the petitioner's claims would breach the ecclesiastical-abstention doctrine (at 1-2).

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No general immunity from tort liability

However, Justice Lehrmann noted that a church is not immune from tort liability merely because it is a church. Nor may a church transform a tort or crime into protected religious conduct merely by enacting a policy that touches on it (at 1-2).