United States Conference of Catholic Bishops v. David O'Connell
For over 1,000 years, Catholics have given an annual offering to the Pope called Peter's Pence. A parishoner claims he was misled during Mass by an invitation from the pulpit that imprecisely described the Pope's use of Peter's Pence. He sued the U.S. Conference of Catholic Bishops, seeking discovery into the donors to, uses of, and internal deliberations about Peter's Pence. He requests an injunction restraining how the Church describes and uses the offering, and a refund for himself and a class of millions of donors.
The Bishops moved to dismiss under the Religion Clauses' church autonomy doctrine. The district court refused, holding the dispute could be resolved under the "neutral principles" approach developed for church property disputes. The D.C. Circuit dismissed the Bishops' interlocutory appeal, concluding that church autonomy provides only a defense against liability, not a structural immunity from suit, and that the "neutral principles" approach avoided "any violations" of church autonomy.
The questions presented are:
1. Whether church autonomy provides a structural limit on state power that protects churches from the burdens of litigating unconstitutional claims.
2. Whether a church may immediately appeal a dispositive church autonomy defense that was denied on legal grounds.
3. Whether the "neutral principles" approach applies outside the church property context to a dispute over a church's description and use of an offering that was used solely for religious purposes.
Whether church autonomy provides a structural limit on state power that protects churches from the burdens of litigating unconstitutional claims; Whether a church may immediately appeal a dispositive church autonomy defense that was denied on legal grounds; Whether the 'neutral principles' approach applies outside the church property context to a dispute over a church's description and use of an offering that was used solely for religious purposes