What is the Catholic Church? This is the central legal question in the case Roman Catholic Archdiocese of San Juan Puerto Rico v. Feliciano. The main case is full of convoluted, jurisdictional issues only a civil procedure professor could love. In essence, a plaintiff in Puerto Rico sued the “Roman Catholic and Apostolic Church of Puerto Rico” in a dispute about pension funding. But, the Catholic Church says there is no such entity recognized under church law. Instead, the Catholic Church argues that its legal personality is separately divided into individual dioceses and archdioceses.
Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof . . .
First Amendment to the United States Constitution
After several rounds of legal appeals, the Supreme Court of Puerto Rico ruled that the Treaty of Paris recognized the “Roman Catholic and Apostolic Church of Puerto Rico” as a separate legal personality. Although the court recognized that the dioceses and archdioceses in Puetro Rico operate separately, they are merely a “fragment of only one entity that possesses legal personality.”
Archdiocese of San Juan Appeals
The Archdiocese of San Juan appealed to the United States Supreme Court. In a decision issued today, February 24, 2020, SCOTUS punted on the central issue of what is the Catholic Church? (For those unfamiliar with the acronym, SCOTUS stands for “Supreme Court of the Untied States.”) Instead, SCOTUS reversed the Supreme Court of Puerto Rico on a narrow jurisdictional issue, with which I will not bore you.
But, SOCTUS recognized the exceedingly important first amendment issues raised by this case.
The First Amendment to the United States Constitution says: “Congress shall make no law respecting an establishment of religion, or prohibiting the free exercise thereof. . .” Generally, the first amendment prevents the government from compelling its citizens to practice (or refrain from practicing) religion. Most people are aware of popular Establishment Clause cases that restrict prayer at school football games and graduations. But the prohibition goes both ways.
Supreme Court Punts on What is the Catholic Church
The Establishment Clause also restricts the government from interfering with internal church structure or discipline. Therefore, courts in the United States accept a church’s decision concerning ecclesiastical rule, custom, or law. In this case, the Catholic Church divides the territory of Puerto Rico into separate and independent jurisdictions. The Catholic Church does not recognize any jurisdiction known as the “Roman Catholic and Apostolic Church of Puerto Rico.” Therefore, the Supreme Court of Puerto Rico violated the Establishment Clause by reforming the Catholic Church’s legal personality from the bench.
The United States argued in favor of the Archdiocese of San Juan and additionally pointed out that the Supreme Court of Puerto Rico “relied on a special presumption — seemingly applicable only to the Catholic Church.” Therefore, it argued that the Supreme Court of Puerto Rico violated the Free Exercise Clause by singling out the Catholic Church for discriminatory treatment.
Unfortunately, as discussed above, the Supreme Court did not address these very important first amendment issues. However, Justice Alito penned a concurrence outlining the need for the court to address these important issues soon.
Why is this battle important? Allowing courts to define what the Catholic Church is, violates fundamental freedoms guaranteed by the First Amendment.There is no freedom of religion if the government is allowed to sit as a quasi-ecclesial judicatory. Churches ought to decide for themselves how they should be formed, structured, and operated. Limiting this expression of religious freedom to what the government considers “proper form” is a severely dangerous precedent. Luckily, SCOTUS did not agree with the Supreme Court of Puerto Rico. Sadly, SCOTUS did not explicitly settle these important issues.
If you would like to read the Supreme Court Order, click HERE.
If you would like to read other orders of the Supreme Court of the United States, click HERE.
