John Doe JP v. Archdiocese of N.Y.

Summary

The Appellate Division, First Department unanimously affirmed an order requiring the Archdiocese of New York to disclose its Tribunal Laicization File concerning former priest Francis J. Stinner, subject to redactions of Social Security numbers and dates of birth. The court held that the requested records were reasonably calculated to lead to relevant evidence concerning alleged abuse, the Archdiocese’s knowledge, and its response, and that the discovery did not implicate canon law or sacramental issues sufficient to raise a First Amendment concern.

Holdings

1. Supreme Court providently exercised its discretion in directing the Archdiocese to produce an unredacted copy of the Tribunal Laicization File, subject to redactions of social security numbers and dates of birth, because the demands were reasonably calculated to lead to relevant and admissible evidence.
2. The First Amendment did not bar discovery because the Archdiocese failed to demonstrate that the requested information implicated canon law or sacramental issues, and the appeal did not contest or address the laicization decision or the religious doctrine underlying it.

Questions Presented

1. Whether Supreme Court providently exercised its discretion in directing the Archdiocese to disclose the Tribunal Laicization File after in camera review.
2. Whether production of the file implicated canon law, sacramental issues, or religious doctrine in a manner creating a First Amendment bar to discovery.

Disposition

affirmed