McEnroy v. Saint Meinrad School of Theology

713 N.E.2d 334 (1999)

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McEnroy v. Saint Meinrad School of Theology

Indiana Court of Appeals
713 N.E.2d 334 (1999)

Facts

Dr. Carmel McEnroy (plaintiff) was a professor of theology and doctrine at Saint Meinrad School of Theology, a Catholic seminary. Dr. McEnroy’s contract with Saint Meinrad stated that the terms relating to appointment and dismissal contained in the Faculty Constitution were “among” the terms of her appointment. In addition, the Faculty Handbook and Statement of Governance of Saint Meinrad were also incorporated into Dr. McEnroy’s contract. Saint Meinrad’s Statement of Governance stated that the seminary operates in accordance with the Catholic Church’s canon law. In 1994, Pope John Paul II issued an Apostolic Letter stating that women could not be ordained as priests. Dr. McEnroy, along with 1,500 others, signed an open letter to Pope John Paul II, opposing this decision. As a result of her public disagreement with the Pope, Dr. McEnroy was removed from the faculty at Saint Meinrad. Dr. McEnroy filed a lawsuit against Saint Meinrad, alleging breach of contract, intentional interference with a contract, and breach of an implied covenant of good faith. Saint Meinrad filed a motion to dismiss, arguing that Dr. McEnroy’s lawsuit would require the court to decide religious issues and apply religious doctrine. The trial court agreed and dismissed the lawsuit. Dr. McEnroy appealed.

Rule of Law

Issue

Holding and Reasoning (Rucker, J.)

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