Federal court dismisses ACLU's "theological malpractice" lawsuit

A federal district court in Michigan yesterday dismissed the ACLU's "theological malpractice" lawsuit against the United States Conference of Catholic Bishops and current and former chairs of a Catholic hospital network. For background on the case of Means v. United States Conference of Catholic Bishops, see my earlier Mirror of Justice post (with links to other coverage).

The filing of this case made a big media splash; its dismissal, not so much. Compelling factual allegations are more interesting than careful dissection of a novel legal theory, I suppose. 

The court concluded that it lacked personal jurisdiction over the USCCB and that plaintiff failed to state a claim upon which relief can be granted against the other defendants. There is some discussion of what the court describes as ecclesiastical abstention, which the court found would have applied to the elements of breach and proximate cause. But the plaintiff would have failed to state a claim upon which relief can be granted even in the absence of that doctrine. The court held that plaintiff failed to identify a legal duty owed plaintiff by the individual defendants. In the court's words, "Plaintiff has not sufficiently demonstrated that Michigan law recognizes a duty to a patient by a sponsor of a hospital network." 

I am already seeing expressions of dismay and outrage in various quarters one would expect to see them. But the court's application of plain-vanilla legal principles seems unobjectionable. People who want to express their opinion should probably read the court's opinion first.