The case turns on whether judges may examine how bishops and priests described the purpose of the offering, or whether such questions are protected from state scrutiny by the First Amendment.

Peter’s Pence has long been presented as an annual expression of solidarity with the Pope and his mission. 

In the United States, the bishops describe it as supporting humanitarian initiatives, social projects and the work of the Holy See itself. 

The plaintiff, David O’Connell, filed suit in 2020 arguing that Catholics were led to believe the collection was directed solely to urgent charitable relief, when in fact some of the money also went towards Vatican administrative costs.

David O’Connell filed a class action lawsuit against the United States Conference of Catholic Bishops (USCCB) for fraudulent solicitation of donations. O’Connell alleged that USCCB misled donors about the use of funds collected through the Peter’s Pence Collection, which were purportedly for emergency assistance but were instead used for investments and other purposes. 

O’Connell claimed that if he had known the true use of the funds, he would not have donated.

The United States District Court for the District of Columbia denied USCCB’s motion to dismiss the case, which was based on the church autonomy doctrine. 

The District Court found that O’Connell’s claims raised a secular dispute that could be resolved using neutral principles of law, without delving into religious doctrine. 

The court emphasized that it would not address purely religious questions if they arose during litigation.

The United States Court of Appeals for the District of Columbia Circuit reviewed the case. The court dismissed USCCB’s appeal for lack of jurisdiction, stating that the collateral order doctrine did not apply. 

The court held that the church autonomy defense could be adequately reviewed on appeal after a final judgment, and that the denial of the motion to dismiss was not conclusive or separate from the merits of the case. 

The court emphasized that the church autonomy doctrine does not provide immunity from suit but serves as a defense to liability. 

The appeal was dismissed, and the case was remanded to the District Court for further proceedings.