Kubala v. Hartford Roman Catholic Diocesan Corp.
2011 WL 7629495, 52 Conn. Supp. 218, 41 A.3d 351 (2011)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
The First Amendment's Establishment and Free Exercise Clauses bar civil courts from exercising subject matter jurisdiction over tort claims that would require an evaluation of the standard of care for conducting a religious ritual, as such an inquiry would create excessive entanglement with religious doctrine and practice.
Facts:
- Dorothy Kubala voluntarily attended a Catholic Charismatic Renewal healing service at St. Augustine’s Church, which was open to the general public.
- The service was presided over by Father Robert Rousseau.
- During the service, Kubala approached the altar to be prayed over.
- As part of the ritual, she experienced a phenomenon known as 'resting in the spirit,' which caused her to fall backward.
- Kubala was not caught by a 'catcher' and fell, hitting the back of her head on the floor.
- As a result of the fall, Kubala suffered severe and painful injuries.
Procedural Posture:
- Dorothy Kubala commenced a negligence action against Robert Rousseau, St. Augustine’s Church, and the Hartford Roman Catholic Diocesan Corporation in the Connecticut Superior Court, a trial court.
- The defendants filed a motion to dismiss the complaint for lack of subject matter jurisdiction, arguing the claim was barred by the First Amendment.
- The plaintiff filed an objection to the defendants' motion to dismiss.
- The trial court heard oral arguments on the motion to dismiss.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does a civil court have subject matter jurisdiction to adjudicate a negligence claim arising from injuries sustained during a religious healing service, where evaluating the claim would require the court to define the standard of care for conducting that religious ritual?
Opinions:
Majority - Alexander, J.
No. A civil court does not have subject matter jurisdiction because adjudicating the negligence claim would require an impermissible inquiry into religious doctrine and practice, violating the First Amendment. To determine negligence, the court would have to define the standard of care for a religious healing ritual, including whether 'catchers' are required, how many are needed, their proper training, and other safety protocols. This is not a matter that can be resolved by applying neutral principles of secular law; it is an ecclesiastical question that would entangle the court in religious matters. Unlike claims of sexual abuse by clergy, which involve conduct universally proscribed by secular law, this claim is inextricably intertwined with the performance of a religious practice. The plaintiff’s claim is effectively one of 'clergy malpractice,' a cause of action uniformly rejected by courts because it would require secular courts to establish professional standards for clergy. Finally, the plaintiff has not demonstrated a compelling state interest of the 'highest order' that would outweigh the defendants' First Amendment protections.
Analysis:
This decision reinforces the ecclesiastical abstention doctrine, which limits the power of civil courts to adjudicate disputes involving religious doctrine or internal church governance. The court draws a critical distinction between torts that are secular in nature (e.g., a slip and fall on a wet floor in a church) and those inextricably linked to the performance of a religious ritual. By classifying this claim as nonjusticiable, the ruling effectively grants religious organizations immunity from negligence suits concerning the manner in which they conduct their religious services. This precedent solidifies the principle that courts cannot establish a 'reasonable' standard of care for spiritual practices, leaving participants to assume the risks inherent in such activities.
