Doe v. Hartz

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Determined the right to sue a parish priest and diocese for sexual misconduct and demand civil remedies under VAWA.

Full Case Title: 

Doe v. Hartz, 970 F. Supp. 1375 (N.D. Iowa 1997), rev'd, 134 F. 3d 1339 (8th Cir. 1998)
  • Fairness in the Courts
  • Violence Against Women and Girls


  • Authored Amicus Brief


Summary of the Case

The plaintiff in this case brought a Violence Against Women Act ("VAWA") civil rights claim against her parish priest (and the diocese) for sexual misconduct. The defendants filed a motion to dismiss, challenging the constitutionality of the VAWA remedy, which was denied.


The Eighth Circuit Court of Appeals reversed the lower court decision in part, stating that the acts alleged did not rise to the level of a felony under state or federal law. The panel did not address the constitutional issue. A request by the plaintiff for reconsideration and a rehearing en banc was denied. Shortly thereafter, the case was settled. The United States Supreme Court later ruled in United States v. Morrison that the VAWA civil rights remedy is unconstitutional.