A Philadelphia Court has dismissed a suit brought by an Episcopal priest alleging the Rt. Rev. Charles E. Bennison, Jr., had defamed him in a letter to the congregation of All Saints Episcopal Church where the bishop revoked the priest’s license to officiate in the Diocese of Pennsylvania.
The Rev. Jeremy Warnick, a priest canonically resident in the Diocese of Arizona but licensed to serve in Pennsylvania, brought suit against Bishop Bennison, All Saints Church and three members of the congregation after he was removed from his position. Upset with his plan to radically restructure the parish and perturbed that he was living in the rectory with a woman who was not his wife and over statements he made about his sexual inclinations in a Facebook post, the parish voted to convert Mr. Warnick’s position into a half time post and also sought the bishop’s assistance in removing him from office.
Mr. Warnick filed a canonical complaint against Bishop Bennison, and when that was dismissed he filed his civil lawsuit. The Court in Warnick v. All Saints Episcopal Church, (PA Com. Pl., April 15, 2014), held that the First Amendment requirement of deference to ecclesiastical courts and the ministerial exception doctrine required dismissal of the complaint.
The court further stated that even if all the claims were not barred by the First Amendment, “Father Warnick’s claims fail as a matter of law because the undisputed evidence shows that necessary elements have not been shown for defamation, contract and civil conspiracy claims.”
