Supreme Court sends back case against Puerto Rican archdiocese

Washington D.C., Feb 25, 2020 / 12:10 pm

The Supreme Court has sent a case concerning the Archdiocese of San Juan, Puerto Rico, back to Puerto Rican courts, overturning a previous decision against the Church which it said would be a First Ammendment violation.

The case involves a lawsuit against the archdiocese over a failed pension fund for Catholic school teachers. The Puerto Rican Supreme Court had ruled that "the Roman Catholic Church" could be recognized as a single legal entity, responsible for all Catholic institutions even if they were separately legally incorporated.

The court announced its decision in Roman Catholic Archdiocese of San Juan, Puerto Rico v. Yali Acevedo Feliciano, et al. on Monday, Feb. 24. The Supreme Court vacated the judgment of the Puerto Rico Supreme Court, and ruled that the Puerto Rico Court of First Instance did not have proper jurisdiction to rule on the case. 

The case concerned the 2016 decision by the Archdiocese of San Juan to terminate a pension plan for employees of Catholic schools in the archdiocese. The pension trust was created in 1979. The case was brought forward by retired and current employees of three schools in the U.S. territory. 

In the initial lawsuit, the defendants were listed as the "Roman Catholic and Apostolic Church of Puerto Rico," the Archdiocese of San Juan, the schools' Superintendent, the pension trust, and the three Catholic schools in Puerto Rico. 

After the lawsuit made its way through the Puerto Rico courts, the Puerto Rico Supreme Court found that "if the Trust did not have the necessary funds to meet its obligations, the participating employers would be obligated to pay." 

When the Puerto Rico Supreme Court remanded the case back to the Puerto Rico Court of First Instance, that court decided that the "Roman Catholic and Apostolic Church in Puerto Rico" was the only entity with separate legal personhood, rather than any of the other defendants. The Archdiocese and other defendants were determined by the Puerto Rico Supreme Court to be a "division or dependency" of the Church as a whole.

The Catholic Church in Puerto Rico was subsequently ordered to make payments to the employees formerly covered by the pension plan, and the Church was required to pay $4.7 million into an a court account. The Puerto Rico Supreme Court also issued an order which required law enforcement to "seize assets and moneys of … the Holy Roman Catholic and Apostolic Church, and any of its dependencies, that are located in Puerto Rico."

When that verdict was appealed to the Puerto Rico Court of Appeals, it was reversed. That court found that "Roman Catholic and Apostolic Church in Puerto Rico" is a "legally nonexistent entity." Instead, the Puerto Rico Court of Appeals ruled that the Archdiocese of San Juan or the schools themselves would be the ones to make pension payments. 

Following further appeals, the Archdiocese of San Juan petitioned the Supreme Court of the United States to hear their case. The Supreme Court received the petition for writ of certiorari on January 14, 2019.

In the per curiam decision, the Supreme Court returned the case to Puerto Rico, with the added stipulations that the Puerto Rico Court of First Instance lacked jurisdiction in the case. 

The Supreme Court also noted that Puerto Rico Supreme Court decision could violate the First Amendment because it "relied on a special presumption--seemingly applicable only to the Catholic Church…--that all Catholic entities on the Island are 'merely indivisible fragments of the legal personality that the Catholic Church has.'"

By singling out the Catholic Church, the Puerto Rico Supreme Court "thus violated the fundamental tenet of the Free Exercise Clause" that prohibits unequal treatment of religious beliefs and denominations. 

Justice Samuel Alito wrote a concurring opinion in the case, joined by Justice Clarence Thomas, adding commentary on "other important issues that may arise on remand." 

Alito wrote that the Supreme Court of Puerto Rico erred in its interpretation of past cases in making its decision in the case Roman Catholic Archdiocese of San Juan, Puerto Rico v. Yali Acevedo Feliciano.

"The Supreme Court of Puerto Rico held that Ponce decided that in Puerto Rico the Catholic Church is a single entity for the purposes of civil liability. That was incorrect," wrote Alito.

Alito said that the misinterpretation of the Ponce case would have been enough to reverse the Supreme Court of Puerto Rico's decision, had the issue regarding proper jurisdiction not been raised, plus the First Amendment violations.

"The Free Exercise Clause of the First Amendment at a minimum demands that all jurisdictions use neutral rules in determining whether particular entities that are associated in some way with a religious body may be held responsible for debts incurred by other associated entities," said Alito.