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Who's the patron saint of disappointed postulants?

By Rebecca Tushnet

Hoyle v. Dimond, 2009 WL 604899 (W.D.N.Y.)

Defendants operate the not-for-profit Most Holy Family Monastery (MHFM). Hoyle entered the monastery in 2005, intending to become a Benedictine monk. Defendant Frederick Dimond (who goes by the name Brother Michael Dimond, OSB) told Hoyle that MHFM dated to the 1960s and that Dimond was a Benedictine monk who supervised the monastery. Hoyle gave MHFM cash of over $65,000, then decided to become a postulate, which Dimond told him required him to turn over his worldly possessions to MHFM. Hoyle thus gave MHFM $1.2 million in stock, then executed a document stating he was to receive $750,000 if he left the monastery. He later found out that MHFM was not a Benedictine monastery, that Brother Michael was not a member of the Order of St. Benedict, and that he couldn?t become a Benedictine monk through MHFM. He sued to recover money he donated to MHFM in reliance on its representations regarding its affiliation with the Order of St. Benedict, alleging fraud, negligent misrepresentation, unjust enrichment, and money had and received.

Defendants argued that the court lacked subject matter jurisdiction under the First Amendment, because the dispute couldn?t be resolved without interpreting religious doctrine, specifically what it means to be ?Benedictine.? Hoyle rejoined that the fraud issue was one of affiliation: were the defendants affiliated with the ?universally recognized and sanctioned? Order of St. Benedict?

Courts can?t resolve controversies that require resolution of matters of religious doctrine. But they can decide disputes if they don?t have to rely on religious doctrine to do so, applying neutral principles of secular law. Hoyle has the burden of showing subject matter jurisdiction, and favorable inferences aren?t drawn in his favor. For purposes of the motion to dismiss, the court accepted the allegations that the defendants represented themselves as Benedictine; that defendants aren?t members of the recognized Order of St. Benedict; and that they convinced Hoyle to turn over his worldly possessions ot him on the false promise that he could become a Benedictine monk. Whether defendants are associated with the recognized Order of St. Benedict can be determined using neutral principles. The dispute is not between MHFM and the Order of St. Benedict, but between Hoyle and MHFM. But, if after discovery, it becomes clear that resolving the dispute would require ruling on religious doctrine, the question could be revisited.

Full post as published by 43(B)log on March 19, 2009 (boomark / email).