BEALS v. St. Clare's Church, et al., Defendants. (2025)

Order, Supreme Court, New York County (Sabrina B. Kraus, J.), entered January 31, 2025, which, after in camera review, directed defendant Roman Catholic Archdiocese of New York to produce unredacted materials from its Tribunal File concerning disciplinary proceedings against former priest Ralph Gregory LaBelle, unanimously affirmed, without costs.

Supreme Court providently directed the Archdiocese to produce an unredacted copy of the file of the Tribunal proceedings against defendant LaBelle, which contains allegations by individuals concerning his behaviors, because the information sought could lead to the discovery of relevant and admissible evidence (see Twenty Four Hour Fuel Oil Corp. v. Hunter Ambulance, 226 A.D.2d 175, 175, 640 N.Y.S.2d 114 [1st Dept. 1996]).  Specifically, whether the Archdiocese was aware of the possible danger the priest posed, whether the priest engaged in patterns of abuse, and whether the Archdiocese acted reasonably to protect children from being sexually abused (see J.L. v. Archdiocese of N.Y., 236 A.D.3d 569, 569–570, 231 N.Y.S.3d 28 [1st Dept. 2025];  T.B. v. Roman Catholic Archdiocese of N.Y., 237 A.D.3d 529, 529–530, 232 N.Y.S.3d 20 [1st Dept. 2025];  McNierney v. Archdiocese of N.Y., 221 A.D.3d 489, 489, 199 N.Y.S.3d 55 [1st Dept. 2023]).

Nor does the fact that documents in the Tribunal file post-date the latest abuse alleged in the complaint require a different result.  The requested materials potentially contain admissible modus operandi evidence (see J.L., 236 A.D.3d at 569–570, 231 N.Y.S.3d 28;  T.B., 237 A.D.3d at 529–530, 232 N.Y.S.3d 20), or potentially evince a patterned response to abuse allegations (see Melfe v. Roman Catholic Diocese of Albany, N.Y., 196 A.D.3d 811, 814, 151 N.Y.S.3d 233 [3rd Dept. 2021]).

Furthermore, discovery of the material does not violate the Archdiocese's First Amendment rights.  While the records concern the church's removal of LaBelle from the priesthood, this action does not contest or in any way implicate that decision or the religious doctrine upon which it was based (cf.  Hosanna–Tabor Evangelical Lutheran Church & Sch. v. EEOC., 565 U.S. 171, 132 S.Ct. 694, 181 L.Ed.2d 650 [2012];  Matter of Congregation Yetev Lev D'Satmar, Inc. v. Kahana, 9 N.Y.3d 282, 286, 849 N.Y.S.2d 463, 879 N.E.2d 1282 [2007]).