The Connecticut Supreme Court ruled Monday that a former Catholic school principal cannot sue the Archdiocese of Hartford on claims she was wrongly fired for not retaliating against a student, who complained about sexual remarks allegedly made by a priest now accused of abusing children.
The high court unanimously overturned a lower court ruling in favor of Patricia Dayner, former principal of St. Hedwig's School in Naugatuck. Justices said Dayner's lawsuit against the archdiocese was barred under the "ministerial exception" to state courts' authority to decide employment cases. The exception is based on the First Amendment right to freedom of religion, and the right of religious organizations to control their own internal affairs.
But the state Supreme Court, in its first ruling on the issue, didn't ban all labor-related lawsuits against religious institutions. Justices adopted the view of the 2nd U.S. Circuit Court of Appeals in New York, which ruled in 2008 that courts can decide to step into church employment disputes based on the nature of the complaints and whether court action would intrude on churches' right to decide issues related to doctrine or internal governance.
Federal appeal courts have issued conflicting rulings in ministerial exception cases. The U.S. Supreme Court will take up the issue later this year, when it hears a case involving a teacher at a church-run school in Michigan and decides whether ministerial exception applies to the Americans with Disabilities Act in cases where church workers are deemed secular, and not religious, employees.
In Dayner's case, she alleged her contract was not renewed for the 2005-2006 school year because she refused to retaliate against an eighth-grade girl who complained in 2003 that St. Hedwig Parish's pastor, the Rev. Stephen Bzdyra, used sexually explicit language in a weekly religious class that made several girls uncomfortable. What exactly Bzdyra allegedly said isn't clear.
Dayner's lawsuit claims Bzdyra denied the allegations and ordered her to report the girl to the Department of Children and Families. Dayner refused.
Lawyers for Bzdyra and the archdiocese said Bzdyra wasn't happy with how Dayner handled the situation, but he renewed her contract for the 2004-2005 year. They said Bzdyra had several serious concerns about Dayner's performance as principal, including the school's failure to receive accreditation, that led to her contract not being renewed the following year.
Bzdyra has been on administrative leave since July 2010 when the archdiocese suspended him amid sexual abuse allegations, which he denies. Three men have filed lawsuits claiming Bzdyra sexually abused them when they were boys.
Dayner's lawsuit alleged that the archdiocese breached implied contracts, including not giving her the chance to improve any deficiencies as principal. It also accused the archdiocese of wrongful termination, and Bzdyra of "malicious actions" that led to her contract not being renewed. She sought an undisclosed amount of damages, lost wages and attorney's fees.
The state Supreme Court on Monday ordered a lower court to dismiss Dayner's lawsuit.
"Her claim essentially asks the court to police the archdiocese's compliance with its own internal procedures," Justice Flemming L. Norcott Jr. wrote in the ruling. "The very act of litigating a dispute that is subject to the ministerial exception would result in the entanglement of the civil justice system with matters of religious policy, making the discovery and trial process itself a First Amendment violation."
Dayner's lawyer, Henry Murray, said he and his client have mixed feelings about the ruling
"We wish that the Supreme Court would have decided the facts differently and allowed the case to go to trial," he said.
But Murray added that he and Dayner were "gratified" that the high court set a precedent that didn't prohibit all lawsuits by religious employees.
A lawyer for the archdiocese, Lorinda Coon, declined to comment on Monday's ruling.
The archdiocese said in a statement that it was "particularly gratified that the Connecticut Supreme Court has recognized in very clear terms that under the Constitution, religious organizations have an exclusive right to decide for themselves matters of doctrine and internal governance and organization, including employment decisions concerning religious leaders, free of interference by the civil justice system."
Dayner didn't immediately return a phone message, and no one answered the phone at Bzdyra's home in New Haven on Monday.