Howard Friedman, Religion Clause
In Hoyle v. Dimond, (WD NY, June 22, 2012), a New York federal district court dismissed fraud, misrepresentation, RICO, deceptive practices, false advertising and equitable claims by plaintiff Eric Hoyle who was seeking return of part or all of the over $1 million that he had donated to the Most Holy Family Monastery (MHFM). Hoyle, who rejected his Protestant faith, became a “traditional” Catholic and joined MHFM in 2005 in part because it was consistent with his beliefs that rejected the Vatican II changes to the Catholic Church and did not recognize post-Vatican II Popes as valid. In 2007, Hoyle left MHFM and set up his own website condemning it as heretical. In his lawsuit, Hoyle asserted that MHFM had misrepresented its historical connections to the Benedictine Order, which her relied on in choosing it. The court concluded:
… [E]ach of plaintiff’s claims is based on his assertion that the defendants misrepresented their status as Benedictine monks and the affiliation of MHFM with the Order of Saint Benedict. Questions regarding the establishment of MHFM as a Benedictine community and its current identification as a “traditional” Catholic Benedictine monastery are matters of religious doctrine over which the court has no jurisdiction. Moreover, plaintiff has failed to raise a genuine issue of material fact regarding the establishment of MHFM.