Civil Suits by Catholic Priests: A Status Report

An interesting look at civil suits filed by Priests to address some alleged wrong, the hurdles they face in doing so, and the outcome of several known cases.

From Catholic World Report

By Michael J. Mazza, JCL, JD

Recent press coverage of a civil suit alleging defamation and fraud brought by a diocesan priest in Indiana against his own diocese and vicar general has triggered a great deal of discussion about the prudential wisdom, legal strategy, and ecclesial consequences of American Catholic priests relying on civil litigation to seek redress against perceived wrongs.

In this context, an explanation of some of the many legal issues involved—under both civil and canon law—might help better inform the debate. In addition, a brief survey of recent cases shows how perilous such a strategy might be, however sympathetic the underlying claims might appear.

Civil Legal Obstacles to Defamation Claims

1. Free Speech

As a general matter, plaintiffs in defamation actions face significant hurdles in the United States. The U.S. Supreme Court has effectively discouraged many defamation claims, ostensibly in defense of the First Amendment’s protection of “free speech.” In the seminal 1964 case of New York Times v. Sullivan, the Court imposed an “actual malice” standard on plaintiffs who are “public officials,” requiring such claimants to show that the author of the allegedly defamatory statements knew that the published information was false or was reckless in deciding to publish it. Ten years later, in Gertz v. Robert Welch, Inc., the Court expanded the notion of “public officials” to include even “public figures,” evidently on the basis that if people decide to enter a public arena, they should be prepared to deal with criticism; given that they are engaged in public debate, they presumably have the opportunity to defend themselves against such attacks.

Not yet clear, however, is just what type of conduct propels one into the public spotlight. It is interesting to consider, for example, whether a Catholic priest would be seen as a “public figure” by virtue of his position, his participation on social media, or perhaps even by his preaching. Either way, one of the several preliminary hurdles a priest would face is whether his alleged defamer had a “free speech” right that would be unduly infringed if a defamation suit was allowed to stand. Whether constitutional concerns even apply to such cases is not at all clear in light of case law; some state courts have afforded “constitutional protection” to non-media defendants (e.g., private citizens not engaged in media reporting), while others have not.

2. Religious Freedom

Priests alleging defamation would likely face another First Amendment obstacle as well, particularly if the object of their lawsuit is a church entity, or if one of the defendants is a Catholic cleric exercising his duties, such as a bishop or a vicar general. Under what is known generally as the ecclesiastical abstention doctrine, civil courts will avoid getting involved when a matter even appears to touch on an intra-ecclesial squabble. The argument is that the First Amendment’s Religion Clauses prevent a secular court from intruding on matters involving the free exercise of religion of the personnel involved.

While priests are generally considered employees of the diocese in which they are incardinated under both state and federal law, they are generally treated as “self-employed” for purposes of the Social Security and Medicare system (as clergy were originally excluded from the Social Security system when it was first established in the 1930s, and only later were allowed to participate in it as “self-employed” participants). This means that a priest’s dispute with his diocese will require a civil court to wade into what is seen as the murky waters involving the employment practices of religious institutions. In the Hosanna-Tabor case in 2012, the U.S. Supreme Court held unanimously that the Establishment and Free Exercise Clauses of the First Amendment bar lawsuits brought by ministers against their churches claiming they had been fired in violation of employment discrimination laws. While such jurisprudence does not necessarily mean that every decision made by an employer will be protected simply out of deference to religious liberty, the bar is nevertheless rather high. To the extent that a hierarchical church has an internal process for the just adjudication of claims—as does the Catholic Church—such determinations ought to be given great weight by U.S. tribunals.

3. Applicable Standards

Beyond these First Amendment obstacles, defamation plaintiffs must also surmount other threshold matters. The Supreme Court’s Gertz decision prohibited states from imposing common-law rules of strict liability in defamation actions brought by private individuals, thus requiring such plaintiffs to show at least negligent conduct. Thus, private plaintiffs in most defamation actions are required to show that the author of an allegedly defamatory statement knew, or should have known in the exercise of reasonable care, that the statement at issue was either false or would create a false impression in some material respect. Courts in other states (including Connecticut, Montana, South Carolina, and Wyoming) require a showing of a degree of fault greater than negligence but lower than actual malice, while courts in Nebraska and Nevada appear to have adopted the higher “actual malice” standard, at least regarding matters of “public interest or concern.”¹

What standard will be applied in a specific case in a given jurisdiction is difficult to predict; results in defamation cases are fact-specific and can vary widely depending on the particular court hearing the case, especially when private plaintiffs bring actions against private (i.e., non-corporate media) defendants. The picture is even murkier when one considers how the “new media” of blogs and social media sites will affect jurisprudence in this area.²

4. Matters of Public Concern

The fundamental issue of what constitutes a matter of “public concern” is far from settled. If the alleged defamatory statement touches such a matter, the defendants will likely be afforded considerably more protection from defamation claims. If, however, the matter is considered to be merely a private concern, plaintiffs are more likely to prevail. Thus, the subject matter of the allegedly defamatory words could matter a great deal. If, for instance, a lawsuit concerns an allegedly false claim of clerical sexual misconduct involving a minor, would such a claim be considered merely a private concern in the current media environment, or would it be more likely seen to touch upon a matter of public interest? The outcome of the case might hinge largely on the answer to that question.

5. Short Statutes of Limitation

Beyond these substantive legal considerations that are sure to impact defamation suits in U.S. courts lays a minefield of significant statutory issues, generally manifesting themselves at the level of procedure. Because of the many practical and legal obstacles facing defamation plaintiffs, motions to dismiss are granted more often in defamation litigation than in other types of cases. Therefore, even assuming a defamation claim can survive a defendant’s motion to dismiss, it potentially faces another significant procedural difficulty: a brief statute of limitations. While statutes of limitations for tort claims such as defamation vary from state to state, they generally run short, with a range from six months to three years; about half the states permit only a one-year period to file a defamation action. This can present a special difficulty for priests, given that a defamation claim may be time-barred if not filed before a priest’s claim has been fully resolved under canon law. As is well known, the adjudication of a priest’s disciplinary case (or claim for damages) may extend well beyond the applicable statute of limitations under civil law.

6. Anti-SLAPP Statutes

Beyond all the other hurdles described above, a little-known but very powerful state statute may not only prevent certain defamation lawsuits from going forward, but may also punish the plaintiffs. “Strategic Litigation Against Public Participation” (SLAPP) was a legal technique described in the 1990s as the weaponization of lawsuits by the powerful to silence protest or dissent. Several states subsequently created anti-SLAPP statutes, seeking to punish, to one degree or another, those claimants who initiate lawsuits in order to intimidate others, infringing upon their free speech rights. A few of these laws are broad in scope, including those in populous states such as California, Texas, Illinois, and New York. Over half of the remaining forty-six states (as well as the District of Columbia) have some form of anti-SLAPP legislation, with varying degrees of scope and strength.

While the original intent of these statutes may have been to punish large and powerful corporate interests from using litigation as a weapon against the powerless, they have had the effect of establishing yet another hurdle to individuals claiming to have been defamed. In one California case,³ for example, a church published a report on the alleged sexual misconduct of two of its employees. When the two youth ministers sued the church for defamation, the church sought protection under the state’s anti-SLAPP statute. The state appellate court decided that the church had a free speech right to publish its report, given that the subject matter fell within the category of a “public issue or an issue of public interest” for purposes of the anti-SLAPP statute. Additionally, because of these anti-SLAPP statutes, about half of the states in the U.S. provide that a plaintiff who has been determined to have initiated a SLAPP lawsuit must pay the defendant’s legal fees. As a result, plaintiffs alleging that they have been defamed can face very different prospects for success in litigation depending on whether and what kind of anti-SLAPP legislation a state has in place.

Applying such principles to the hypothetical case of a priest accused of sexual misconduct and seeking redress in a civil forum, it is possible that an anti-SLAPP statute will militate against any defamation action he may wish to pursue. An immediate and significant practical obstacle might be finding a civil attorney willing to file such an action, not only because personal injury attorneys in the United States generally work only on a contingency basis—i.e., collecting their fees from a percentage of any eventual recovery for a personal injury such as defamation—but also because of the possibility of the imposition of a judgment ordering the unsuccessful plaintiff (and perhaps his counsel) to pay the often significant legal fees of the defendant’s attorneys.

Theological Issues Relating to Defamation Claims

1. The Pauline Injunction

In addition to the challenges arising under applicable civil law, there are also issues under moral and canon law that priest-plaintiffs must reckon with. The first such issue relates to St. Paul’s chastisement of the Corinthian Church for their litigious habits, often aired in front of unbelievers (1 Cor. 6:1-7). Of course, St. Paul’s own example can be brought up in response to this line of argument: he did, after all, appeal to Caesar in order to defend himself against “the many serious charges” brought against him by the Jews. So the theological reality here is more complex that an immutable rule would allow. Furthermore, canon 221 of the 1983 Code of Canon Law explicitly articulates a right belonging to each and every member of the faithful to “vindicate and defend” the rights they enjoy in the Church before the proper ecclesiastical forum, as well as the right not to be punished “except in accordance with the law.”

2. Counsel on Suffering Injustice

St. Francis de Sales, in his Introduction to the Devout Life, urges a healthy balance when it comes to preserving one’s good name, which he says is “one of the bases of human society,” and without which “we are not only useless but harmful to the public by reason of the scandal it would provoke.” Drawing an analogy to leaves on a tree, he points out that while they are not of great value in and of themselves, they do serve “not only to beautify the tree but also to preserve its tender young fruit.” Likewise, he says, good reputation is not desirable for its own sake, “but it is very useful not only for the adornment of our life but also for preservation of virtue, especially of virtues which are as yet only weak and tender.” Thus, he says, “It is legitimate to be jealous of our reputation but not to be idolatrous of it.” He advises that “[i]f we are condemned unjustly, let us calmly oppose truth to calumny.” He then adds:

If the calumny continues, let us continue to humble ourselves. By surrendering our reputation together with our soul into God’s hands, we safeguard it in the best way possible… Nevertheless, I except from this certain crimes so horrid and infamous that no man should put with being falsely charged with them if he can justly acquit himself of it. I also except certain persons on whose reputation the edification of many others depends. According to the opinion of theologians, in such cases we must quietly seek reparation of the wrong received.⁴

3. Canonical provisions

An argument might also be made that a civil action initiated by a priest runs counter to his promise of obedience to his bishop or superior (cf. cc. 273, 601). Clerics who sue their superiors in civil court may be threatened with canonical penalties under canon 1371 §1 (regarding disobedience to a lawful command or prohibition of an Ordinary or a Superior), canon 1372, 1° (punishing those who interfere with the exercise of ecclesiastical power, or who intimidate one who has exercised such power), and/or canon 1373 (proscribing the public incitement of hatred or animosity against the Holy See or one’s Ordinary and the provocation of disobedience against them).

The key element in the response to such arguments is contained in the venerable maxim from Roman law: “Neminem laedit qui iure suo utitur” (He who exercises a legitimate right harms no one.). If a priest is legitimately defending his rights, it would hardly be just for his bishop to forbid such defense in the name of obedience. Indeed, recourse to the civil forum is contemplated in several places in the 1983 Code, albeit under certain conditions.⁵ A contrary conclusion to what has just been stated would serve to vitiate the entire juridical system built around subjective rights, turning the exercise of ecclesiastical governance into an arbitrary voluntarism. If a cleric does abuse the legal process, however, he may be subject to discipline under not only canon law, but civil law as well.

In any event, it should be noted that even if a violation is found of any of the canons mentioned above (i.e., §§ 1371-1373), there are other Code provisions that would likely work together to mitigate—or totally prevent—any penalty that might otherwise apply. In particular, Canons 1323 and 1324 reflect the Church’s respect for the principle of self-defense, inasmuch as they protect those who act in “legitimate defense” of oneself or in defense of another, whether such defense is executed with due moderation, and whether the person was culpably mistaken about the need for such defensive actions.

Particular Cases

With these civil and canonical legal considerations in mind, we can turn our attention to a list of some of the more prominent recent cases involving clerics who have initiated some kind of civil litigation after having been accused. Some of the cases involve claims against an accuser; others relate to claims against church personnel. While no claim is made as to its exhaustiveness—including only cases reported in the popular press—the list does give at least some indication of the paucity of reported legal “victories” in the civil sector.

1) A 2004 news article in The Los Angeles Times highlighted a case filed by Msgr. Joseph Alzugaray in Los Angeles County Superior Court against his accuser.⁶ The article noted that the priest had also taken the “rare legal step” of suing the organization “Survivors Network for those Abused by Priests” (SNAP), which had published his name on the group’s website as being a sexual abuser, even though he had been cleared of the accusation after a 2002 investigation by the Diocese of Santa Rosa.⁷ Lawyers for SNAP filed a motion to strike the lawsuit pursuant to California’s anti-SLAPP law, which the court eventually granted, also awarding legal fees to defense counsel.⁸ Alzugaray retired in 2011 as a priest in good standing from the Diocese of Santa Rosa, and died three years later. Yet as of March 2024 his name still appears on the internet listing of the Archdiocese of Los Angeles, where he was first incardinated, as having been “credibly accused” of sexual abuse.⁹

2) A different result was reached in a 2016 case from Missouri, involving diocesan priest Rev. Joseph Jiang. After being cleared of a false accusation of sexual abuse, Jiang sued, among other defendants, the same SNAP group that Msgr. Alzugaray had sued. Jiang eventually won, and SNAP was forced to pay his attorneys’ fees and issue an apology.¹⁰

3) Rev. Eduard Perrone, a priest of the Archdiocese of Detroit, in August 2020 sued his fellow archdiocesan priest, the Archdiocesan Vicar for Clergy Msgr. G. Michael Bugarin, in Wayne County, Michigan.¹¹ In February 2022, Perrone issued a statement of public apology that was published on the archdiocesan website, where it remains as of this writing.¹² The statement apologized for having filed the lawsuit, which was said to have “caused harm to the reputations of Msgr. Bugarin and the Archbishop and impeded the process of the investigation,” and included a notice that he had instructed his attorneys to “withdraw all pending civil cases and appeals.”

4) Deacon Jesus Guerrero, a permanent deacon in the Diocese of Lubbock, Texas, sued his diocese for $1 million in damages in March 2019, alleging libel and defamation, after the diocese had included his name on a list of clerics against whom a “credible allegation of sexual abuse of a minor” had been made.¹³ The Texas Supreme Court eventually ruled 8-1 in favor of the diocese, claiming that the ecclesiastical abstention doctrine prevented the civil courts of Texas from determining whether the diocese had properly applied Canon Law, including the key question of whether a “minor” included an adult female compromised by mental health issues. In his lone dissent, Justice Boyd listed over a dozen state and federal cases in support of the proposition that defamation lawsuits in ecclesial contexts are not necessarily barred by the ecclesiastical abstention doctrine under First Amendment jurisprudence and case law.¹⁴

5) A case involving the family of a deceased Jesuit priest merits special attention, if only because it did not apparently involve any civil litigation. Rev. Patrick Koch was a Jesuit priest who had served in the Diocese of Dallas. Some thirteen years after his death in 2006, the diocese included his name, along with thirty others, on a published list of those clerics who had been “credibly accused” of sexually abusing minors. A civil attorney representing more than two dozen of the deceased priest’s family members announced that an appeal to the Holy See had been filed under canon law for the removal of the priest’s name.¹⁵ Koch’s name remains on the diocesan website’s list as of this writing.¹⁶

6) In August 2020, Rev. Andrew Syring, a priest of the Archdiocese of Omaha, sued the Archdiocese for more than $2 million in damages, alleging defamation, various other tort actions, and a deprivation of due process after his name was placed on lists published by the archdiocese of “clergy accused of sexual criminal misconduct” and “substantiated claims of clergy sexual abuse or sexual misconduct with a minor.” The archdiocese refused public comment at the time, stating only that the dispute “concerns a personnel issue and involves internal church discipline.”¹⁷ After protracted litigation, the archdiocese prevailed on a motion for summary judgment in 2023, but that decision is at the moment on appeal with the Nebraska Court of Appeals.

7) According to the Associated Press, Rev. Georges de Laire, a priest of the Diocese of Manchester, New Hampshire, won a $500,000 defamation judgment in March 2024 against “Church Militant,” an unofficial Catholic media website that had published an article defaming de Laire. Church Militant later disavowed the article, claiming it had been authored by a canon lawyer whom Rev. de Laire also sued personally and won a default judgment against in 2022.¹⁸

8) Rev. Roy Herberger, of the Diocese of Buffalo, was accused in June 2018, two months after the diocese announced it had created a compensation program for victims of clerical sex abuse. He was immediately removed from ministry and his name was made public by the diocese, even before any investigation into the claim was made. Given the wildly implausible nature of the accusations lodged by the accuser, documented as part of the diocese’s own eventual investigation of the claim, Herberger benefited from a sympathetic news story about his case.¹⁹

In a relatively rare move, Herberger filed a defamation suit in 2020 not against the diocese but rather against his accuser; however, he dropped it in 2023 after he said he could no longer afford to pay his lawyer.²⁰

9) Michael W. Toohey, ordained as a priest for the Archdiocese of St. Louis in 1967 and who voluntarily sought laicization three years later, was included on the archdiocese’s list of former clergy with “substantiated allegations” of sexual abuse of a minor, published in July 2019. In a media interview,²¹ Toohey stated that he was never informed that anyone had accused him before his name was released to the public and that, after he approached the archdiocese for an explanation, he was told only that an unidentified person had come forward with a claim in 2002. Toohey, described as a retired business executive, husband of 49 years, father of three and grandfather of seven, sued the Archdiocese of St. Louis for defamation in December 2019,²² but lost on summary judgment in February 2023 on the grounds that each of his claims was, according to the public posting on the Missouri courts website, “barred by the First Amendment’s Religion Clauses.”

10) J. Patrick Foley, ordained for the Diocese of San Diego in 1973, filed an action for defamation against the diocese in 2019 after it included his name on its “clergy abuse list.”²³ According to publicly available information from the San Diego County Superior Court, the diocese not only won on summary judgment in May 2022 (because “the challenged action arises from speech on matters of public interest”), but it also pressed for, and was awarded, attorneys’ fees under the state’s anti-SLAPP statute, totaling nearly $98,000.

11) Rev. John Onderko, ordained in 1962 for the Diocese of Peoria, sued his diocese in 2020 after the diocese publicly named him as having been accused of abuse of a minor, even though no victim had ever come forward. In a newspaper interview shortly after the lawsuit was filed, Onderko claims never to have been told what the accusation was, that he was not given due process, and that he was suing on behalf of his brother priests against the “intentional, willful, and malicious” conduct of the diocese.²⁴ The case was dismissed in September 2022.

12) Rev. James DeOreo, a priest of the Diocese of Lafayette, Indiana, sued his accuser for defamation in 2022²⁵ and then, in 2024, sued his diocese and the diocesan vicar general, Rev. Theodore Dudzinski, alleging fraud and defamation.²⁶ DeOreo’s case against his accuser was settled in March 2024; he filed his case against the diocese and the vicar general days later. Thus far, the allegations contained in the complaint are as yet unproven.

13) After being falsely accused in 2016 of sexually abusing a high school student in the 1970s, Rev. William C. Graham of Duluth sued his accuser, Terrance Jerome Davis, Jr., in state court. Graham sued not for defamation, but for tortious interference with contract, claiming that Davis’s false claims led to Graham being placed on “administrative leave,” causing him to lose a $500 monthly stipend from the diocese. A jury awarded Graham $13,500 in August 2018, which was affirmed on appeal. Graham’s civil attorney noted in a news interview at the time that the case “was never about money,” but rather “about clearing my client’s name.”²⁷ Over five and a half years later, after Graham successfully made hierarchical recourse against the Diocese’s actions to the Dicastery for the Doctrine of the Faith, the Diocese of Duluth restored Graham’s public faculties.²⁸

Two other reported cases, about which the ultimate resolutions were not publicly available, concern “former priest” William B. Smaltz, who in 2020 sued the Diocese of Youngstown, Ohio for defamation,²⁹ but who ultimately dismissed his own complaint two years later, and a priest of the Society of the Divine Word, Rev. Kenneth Hamilton, who was cited in 2019 press reports as having sued both his religious order and the Archdiocese of New Orleans, alleging that they both had defamed him in the course of settling lawsuits in 2018.³⁰

Conclusion

While civil litigation presents a tempting alternative to recourse under canon law, priests pursuing this path in the United States should be made well aware of the risks and rewards of such a strategy. A short-term rush of publicity may satisfy the desire to make a stand in defense of one’s reputation, but the harsh realities of litigating defamation claims in the U.S. demand attention. This is particularly true at a time when public sentiment seems bent on vengeance rather than justice, and when popular opinion appears disinclined to give fair hearing to a Catholic priest accused of sexual misconduct, regardless of the basis (or lack thereof) for such accusations. The dearth of successful verdicts in favor of clerics who file defamation lawsuits in civil court underscores this reality.

Additionally, not to be disregarded are the potentially severe consequences under canon law for employing the instruments of civil justice. Of course, if a priest feels he has nothing to lose, the civil route might appear more attractive. The list of cases described above, many of which include men who had left active ministry, bears this out. Nevertheless, it is a sad situation indeed that a man ordained to serve God and His Church feels like he has no alternative but to bring suit in the courts of Caesar.

The canonical forum remains the preferable option. While unknown to many Catholics—clergy and lay alike—the 1983 Code of Canon Law specifically incorporates provisions designed to foster the defense of individual rights. Despite a sometimes well-earned reputation for inefficiencies, delays, and conflicts of interest, the ecclesial canon law system provides at least a possible path by which the Church can ensure justice for every member of the faithful, including accused priests.

Endnotes: 

¹ Robert D. Sack, Sack on Defamation: Libel, Slander, and Related Problems, 5th ed. (New York: Practicing Law Institute, 2017), § 6:2.

² For a discussion of the many jurisdictional issues related to defamation lawsuits in the digital age (e.g., whom to sue and where, especially when announcements are posted on an internet site, see Michael J. Mazza, “Defending a Cleric’s Right to Reputation and the Sexual Abuse Scandal in the Catholic Church,” Tulsa Law Review 58, no. 1 (Fall 2022): 77-97, 81-86.

³ Terry v. Davis Community Church, 131 Cal. App. 4th 1534, 33 Cal. Rptr. 3d 145 (2005).

⁴ Francis de Sales, Introduction to the Devout Life, trans. John K. Ryan (New York: Image Books, 1972), 145.

⁵ See, e.g., 1983 Code of Canon Law, c. 22 (“canonizing” certain civil laws to a limited extent); c. 1284 §2 (making compliance with applicable civil law a necessary condition for prudent administration of ecclesiastical goods); c. 1286 (requiring the “meticulous” observance of civil law when employing workers); and c. 1290 (effectively extending the application of relevant civil laws to church-related contracts). It might be argued that canon 1288 aims to restrict litigation in the civil courts, but that applies within the specific context of an administrator of ecclesiastical goods initiating or contesting civil litigation in the name of public juridic person without written permission of their Ordinary.

⁶ Jean Guccione, “Some Priests are Suing Their Accusers,” in The Los Angeles Times (Mar. 5, 2004). See also The New York Times< (Aug. 25, 2002) (quoting a letter from SNAP criticizing a defamation lawsuit filed by a priest as “un-Christian, vengeful-style litigation that may scare others who have been abused and are hurting into remaining silent”).

⁷ Martin Espinoza, “Monsignor Alzugaray consistently denied he abused girl 40 years ago,” in The Press Democrat (Apr. 24, 2010).

⁸ See Alzugaray v. Survivors Network for Those Abused by Priests, Los Angeles County Superior Court, No. BC311107 (2004; accessed Apr. 1, 2024).

⁹ See “Consolidated List of Persons Named in the Report to the People of God with Current Status through March 30, 2021” (accessed Apr. 1, 2024).

¹⁰ Robert Patrick, “St. Louis priest gets apology from anti-abuse group; suit against police is dismissed,” in St. Louis Post-Dispatch (Nov. 27, 2017; accessed Apr. 1, 2024).

¹¹ Jameson Cook and Jamie Cook, “Suspended priest seeks return following favorable ruling from Vatican,” in Royal Oak Tribune (Apr. 29, 2021; accessed Apr. 1, 2024).

¹² “Statement of Public Apology from Reverend Eduard Perrone” (February 17, 2022; accessed Apr. 1, 2024).

¹³ Jacob Estrada, “Former Deacon Sues Lubbock Diocese for Defamation,” KFYO.com, Mar. 26, 2019 (accessed Apr. 1, 2024).

¹⁴ In re Diocese of Lubbock, 624 S.W.3d 506 (Tex. 2021).

¹⁵ John Panicker, “Family of Jesuit priest files canon law appeal to Vatican over accused priests list,” WFAA NewsWest9 website, Feb. 12, 2019 (accessed Apr. 1, 2024).

¹⁶ Catholic Diocese of Dallas, “List of priests with credible allegations” (accessed Apr. 1, 2024).

¹⁷ John Chapman, “Priest sues Archdiocese of Omaha for defamation,” WOWT News, Sep. 3, 2020 (accessed Apr. 1, 2024).

¹⁸ Associated Press, “Catholic News Site Church Militant Agrees to Pay $500k in Defamation Case and Is Expected to Close,” Mar. 4, 2024 (accessed Apr. 1, 2024).

¹⁹ Daniel Telvock, “How a priest got cleared of sexual abuse allegations,” WIVB.com, Nov. 11, 2019 (accessed Apr. 1, 2024).

²⁰ Jay Tokasz, “Buffalo priest drops defamation case against accuser alleging sex abuse,” The Buffalo News, June 12, 2023 (accessed Apr. 1, 2024).

²¹ Jesse Bogan, Erin Heffernan, and Nassim Benchaabane, “Catholic Officials Named Them As Abusers: Now These Former St. Louis Clergy Must Face Their Pasts,” St. Louis Post-Dispatch, Sep. 7, 2019 (accessed Apr. 1, 2024).

²² Nassim Benchaabane, “Former priest sues Archdiocese of St. Louis for naming him on list of alleged abusers,” St. Louis Post-Dispatch, Dec. 5, 2019 (accessed Apr. 1, 2024).

²³ Alia Slisco, “Catholic Priest Files Defamation Lawsuit After Being Outed as Alleged Predator,” Newsweek, Sep. 17, 2019 (accessed Apr. 1, 2024).

²⁴ Linda Cook, “Accused Priest in Rock Island Sues Peoria Diocese: ‘I Am Innocent,’” Quad Cities Online, Mar. 10, 2020 (accessed Apr. 1, 2024).

²⁵ Demie Johnson, “Carmel priest sues man who accused him of inappropriate conduct,” WISHTV.com, Apr. 19, 2022 (accessed Apr. 1, 2024).

²⁶ Ann Marie Shambaugh, “Carmel priest sues local diocese, church leadership for defamation, fraud,” Current, Mar. 13, 2024 (accessed Apr. 1, 2024).

²⁷ Mike Mosedale, “Duluth priest successfully sues his accuser,” Minnesota Lawyer, Sep. 24, 2018 (accessed Apr. 1, 2024).

²⁸ Matt C. Abbott, “Vatican acquits Minnesota priest accused of sex abuse,” RenewAmerica.com, Mar. 30, 2024 (accessed Apr. 1, 2024).

²⁹ Ed Runyan, “Former priest files defamation suit,” The Vindicator, Oct. 28, 2020 (accessed Apr. 1, 2024).

³⁰ Ramon Antonio Vargas, “Priest named in settled clergy-abuse claim files defamation suit against New Orleans archdiocese,” NOLA.com, Dec. 18, 2019 (accessed Apr. 1, 2024).