News broke on Saturday that Frank Pavone, the head of a pro-life campaigning organization and controversial political activist, had been dismissed from the clerical state.
A prominent media figure for years, Pavone’s laicization has captured media attention in the U.S., and left many wondering if the Vatican decided to dismiss him from the clerical state because of his stridently pro-life activism and his well-known political beliefs.
Some have claimed that Pavone’s dismissal came in response to his political activities and prominent pro-life work — one bishop even called it “blasphemy.”
So, what’s going on? The Pillar explains.
Frank Pavone is the national director of Priests for Life, a national pro-life apostolate, which in turn supports Rachel’s Vineyard post-abortion healing retreats, manages a publishing division, engages in television production work, and livestreams daily Masses.
Pavone was ordained a priest by Cardinal John O'Connor of New York in 1988, and has served in pro-life leadership positions full-time since 1993.
Pavone has made headlines in recent years because of his avowedly partisan activism, which included a 2016 video in which he placed the body of a dead baby on a table resembling an altar, upon which he sometimes offered Mass, while urging Catholics to vote for Donald Trump.
Since 2016, Pavone has posted tweets, Facebook statuses, videos, and other social media postings urging support for the Republican party, calling into question the validity of the 2020 presidential election, and disparaging Democratic lawmakers. Pavone served as a member of the campaign advisory group “Catholics for Trump” during the election.
In September 2020, his diocese released a statement disavowing tweets from the priest, in which Pavone called then-Democratic presidential nominee Joe Biden a “[expletive] loser” and said the Democratic party was “God-hating” and “America-hating” and that Biden’s supporters “can’t say a [expletive] thing in support of their loser candidate without using the word Trump.”
Originally incardinated in the Archdiocese of New York, the priest transferred his incardination to the Diocese of Amarillo, Texas in 2005, with plans to begin a religious order. The plan fizzled, and Pavone soon found himself clashing with Amarillo's Bishop Patrick Zurek, who was appointed to lead the diocese three years after Pavone arrived there.
Nevertheless, despite his claims to the contrary, The Pillar has confirmed that Pavone remained incardinated in Amarillo until his laicization.
The Amarillo diocese generally does not respond to questions about Pavone’s status as a priest, but its 2020 statement noted that Pavone had “posted a variety of messages and statements in regard to the General Elections in November, 2020.”
“These postings on Social Media as videos concern the serious sinfulness of voting for candidates of a particular political party (with refusal of absolution if confessed) and the use of scandalous words not becoming of a Catholic priest,” the diocese said.
“These postings are not consistent with Catholic Church Teachings. Neither the Catholic Church nor the Diocese of Amarillo condone any of these messages. Please disregard them and pray for Father Pavone.”
The 2020 incidents were part of a decade-long dispute between Pavone and Bishop Zurek. In 2011, Zurek barred Pavone from priestly ministry outside the diocese, and ordered him to return to his diocese and to receive a pastoral assignment.
Pavone did not obey his bishop's orders, and was suspended. The priest began a contentious process of appeal of his bishop's suspension, and claims that the Vatican lifted his suspension in 2019.
When Zurek suspended Pavone in 2011, the bishop cited concerns about Pavone's financial management, and his disobedience.
Zurek said he had “deep concerns regarding his stewardship of the finances of the Priests for Life (PFL) organization” which was then generating more than $10 million in donations a year.
“Father Pavone has gradually lost his need to show appropriate obedience to his bishop,” Zurek wrote at the time. “It seems that his fame has caused him to see priestly obedience as an inconvenience to his unique status and an obstacle to the possible international scope of his ministry.”
In recent years Pavone had claimed to be in the process of transferring to another, undisclosed, diocese, and said he was subject to the authority of the bishop of that undisclosed diocese, rather than to Zurek.
In fact, Pavone claimed in 2020 that he had stepped down from his official roles with the Trump campaign because his new bishop had directed him to, but he declined at that time to name the bishop.
Pavone has repeatedly said that in 2016, he sought a transfer to the Diocese of Colorado Springs, and has claimed that an agreement to make that transfer happen was in 2019 blocked by the Holy See.
But sources familiar with Pavone’s case confirmed to The Pillar that the transfer never happened.
For his part, Bishop James Golka of Colorado Springs said on Monday that he could not confirm Pavone's alleged transfer plans.
“I regret that, in the time that elapsed between my arrival in Colorado Springs and Bishop Sheridan’s death, I did not have the opportunity to speak with him about many of the things that occurred during his tenure, including this matter,” Golka said.
“Therefore, I am unable to comment on Mr. Pavone’s assertion other than to say that he has never been incardinated in the diocese.”
So what happened?
On Dec. 13, the bishops of the United States were informed that Pavone had been laicized on Nov. 9.
In a letter to U.S. bishops, apostolic nuncio Archbishop Christophe Pierre noted that Pavone is a longtime high-profile figure associated with the right-to-life movement, adding that his laicization “may, therefore, be a matter of interest among the faithful.”
In light of that “potential interest,” the nuncio sent to the bishops a brief statement from the Vatican’s Dicastery for Clergy, which said Pavone had been laicized after “canonical proceedings” found him guilty of “blasphemous communications on social media, and of persistent disobedience of lawful instructions from his diocesan bishop.”
The Vatican’s statement also said that Pavone had been given “ample opportunity” to defend himself, and was given several chances to accept his bishop’s authority but had not done so and had given “no reasonable justification for his actions.”
What does ‘laicization’ mean? Is Pavone still a priest?
Priestly ordination confers an indelible character on the man being ordained, as such it cannot be undone — although laicized, Pavone remains a priest, sacramentally speaking.
Those who are “laicized” lose all the rights and privileges of clerics, including the faculties to say Mass, hear confessions (except in danger of death), to receive ministerial assignments, to wear clerical dress, and to be addressed as “Father.”
After a cleric is laicized, he is not automatically free to marry.
Laicized clerics can also be dispensed from the obligation of clerical celibacy, which would make them free to validly contract marriage. But that dispensation is not granted pro forma with dismissal from the clerical state, and it must be specifically granted by the Holy See on request.
It is not clear if a dispensation from celibacy was conferred in Pavone’s case.
And here's a nota bene: While media reports often the use the term "defrock" to describe laicization, the term is never used by clerics themselves, canon lawyers, or Church officials, who use either "laicize" or "dismiss from the clerical state" rather than "defrock."
How does a priest get ‘laicized ?
There are three main ways in which a priest can be laicized by the Church.
The first is by personal petition of the cleric himself to the Holy Father, asking the pope to release him from the clerical state as a “special favor.”
The second ordinary means by which a priest can be laicized is when he is found guilty of a crime in canon law which has dismissal from the clerical state attached as a possible penalty — for example the abuse of minors. Such cases are handled by a different Vatican department, the Dicastery for the Doctrine of the Faith, which does have the authority to impose the penalty of laicization.
The third means by which a priest can be dismissed is by the application of “special faculties” granted to the Dicastery for Clergy by Pope Benedict XVI in 2009.
Pope Benedict granted the dicastery (then the Congregation for Clergy) authority to handle cases in which the local bishop petitions to laicize a priest who has either attempted civil marriage with a woman, violated divine or canonical law in some special aggravating circumstances, or deserted ministry altogether for at least five years.
Under the second of the three circumstances, bishops can petition for the involuntary laicization of a priest in response to “behavior which gravely damages the common good of the Church” and presents public scandal, but only after they have investigated the matter themselves, and tried to admonish and correct the priest.
If corrections and admonishments are ignored or rejected repeatedly, and the bishop sees no other way to deal with the situation, he can appeal to Rome for a priest’s laicization.
The “special faculties” constitute what canon law calls an “extrajudicial process” — meaning that while there is still the presentation of a petition - a kind of canonical indictment in these cases - and the right of legal defense for the priest, there isn’t a formal trial before a tribunal of judges.
Instead, the dicastery assesses a petition from the diocese, presented by the bishop, and makes a decision.
If the dicastery finds in favor of the bishop’s petition, the final decision to laicize the priest has to be made by the pope in every case — though this is often a formality, as the pope usually accepts the dicastery’s recommendation.
What happened in Pavone’s case?
Sources close to the case have confirmed to The Pillar that Bishop Zurek petitioned the dicastery for Pavone’s laicization, making use of the dicastery's “special faculties.”
While media reaction has largely focused on Pavone’s pro-life and partisan political activities, the dicastery judged that he had engaged in “blasphemous communications on social media, and of persistent disobedience of lawful instructions from his diocesan bishop.”
It is not clear which of Pavone’s communications were judged as blasphemous.
Some have pointed to the incident in which the priest placed the body of an aborted child on a table resembling an altar, and which he celebrated Mass — something theologians at the time condemned as a violation of the child’s dignity and an abuse of what appeared to be an altar.
Others, including Pavone himself, have pointed to tweets in which the priest decried “God damned baby killing politicians.”
In the end, neither of those incidents, separately or together, would likely have seen Pavone laicized.
Special faculties cases are almost always judged on the response of clerics to the correction of their bishop after an incident — even a serious one — and not the incident itself.
Sources close to his case have told The Pillar that the Pavone case had less to do with his media profile and public statements, and more to do with his “persistent disobedience” to his bishop.
In short, it seems likely that Zurek cited Pavone’s refusal to accept an assignment, his conflicts with Zurek with over financial questions involving Priests for Life, and whatever Pavone had been directed to do regarding social media, as evidence of a pattern of disobedience that had become intractable.
The dicastery seemingly agreed with that view.
In the statement sent to U.S. bishops, the dicastery noted that Pavone had “multiple opportunities to submit himself to the authority of his diocesan bishop,” but he did not choose to do so.
In short, the Holy See's process indicated that it was Pavone’s persistent disobedience, including his refusal to return to his home diocese and conform to his bishop’s instructions, which led to his laicization.
Why was Pavone laicized and not some abusers? Why not Fr. Heretic?
Some Catholics have asked whether Pavone’s case was “prioritized” over other others, including cases of clerical sexual abuse.
But because cases involving sexual abuse are ordinarily handled by a different dicastery, they are treated by entirely different processes, and teams of staff. Those processes are not beyond criticism, and Pavone’s laicization comes at the same time that the Dicastery for the Doctrine of the Faith has come under heavy criticism for its handling of sexual abuse allegations against Fr. Marko Rupnik, SJ.
The apparent disparity in the handling of Pavone’s case and Rupnik has led to frustration for many Catholics - but it is worth noting that the cases were handled by different Vatican departments, and along different timelines.
Other Catholics have asked why Pavone was laicized, while other priests who reject or defy Catholic doctrine have not faced penal discipline. It’s a fair question, and it points to questions about the willingness of bishops and religious superiors to apply canon law to problematic situations.
But while the Church’s handling of other priests with public ministries is fair fodder for criticism, those cases don’t tie directly into the question of whether Pavone himself was treated with procedural and substantive justice, in a process envisioned by canon law and initiated by his own bishop.
Can Pavone appeal?
No. As the letter from the nuncio to the U.S. bishops made clear, Pavone’s laicization is a “Supreme Decision admitting of no possibility of appeal.”
Because every “special faculties” laicization is presented to the pope for his personal authorization, it is a legal act of the pope himself.
Canon 1366 of the Code of Canon Law constitutes it a crime to attempt to appeal a decision of the pope to either an ecumenical council or to the College of Bishops, the body of bishops in communion with the pope.
Pavone says he was not notified of his laicization, while bishops were informed Dec. 16. Is that possible?
At the conclusion of a “special faculties” process - and after the priest has had an opportunity to make a final defense - the dicastery issues a final decree, relating the “Supreme Decision” in the case.
That decree is sent to the man’s diocese of incardination, and he is requested by a formal letter to present himself at the diocesan chancery, in order for the decision to be communicated to him.
It is possible that Pavone was not yet formally notified of the Church’s final decision, if he was summoned to the Amarillo chancery and did not present himself, or did not otherwise respond to an issued summons. Or it is possible that the summons wasn't sent to Pavone, although most dioceses send such messages by registered mail, in order to complete the process.
While many chanceries send by registered letter a copy of the final decision if a priest does not present himself at the chancery, the Diocese of Amarillo has not responded to questions about Pavone’s laicization process.
What has Pavone said?
On Dec. 17, shortly after the news of his laicization broke, Pavone said on Twitter that “in every profession, including the priesthood, if you defend the unborn, you will be treated like them! The only difference is that when we are ‘aborted,’ we continue to speak, loud and clear.”
Later that evening, the priest live-streamed a long video in which he said that the charge of blasphemy followed an occasion in which he “got really angry at this one guy, it was about a year and half ago, this was bad, it was bad.”
"This guy was a real rabid Biden supporter and criticizing me,” Pavone said, adding that he responded to his interlocutor by criticizing “you and these G-D baby-killing politicians.”
“I shouldn't have said that word, I usually don't,” Pavone said. “At that moment, I was very angry. Sorry. So I went to confession. Sorry."
But Pavone said “one of the bishops who has made it a point to show his animosity toward me” had “turned it into 'Father is doing blasphemous comments on social media.’”
In the Dec. 17 video Pavone appeared in a clerical shirt under a leather biker jacket and, despite his laicization, Pavone's social media account continue to identify him as “Father” and a “Catholic priest.”
What happens next?
The priest canceled a scheduled livestreamed Mass Dec. 19, but Pavone’s public statements, and his continued use of clerical dress and the title “Father,” suggest that he does not accept the Vatican’s decision.
If he continues to present himself as a cleric, Pavone could face new admonitions and warnings from the bishop of the Diocese of Orlando, Florida, where Pavone lives, and where Priests for Life has its headquarters.
Should Pavone ignore those warnings, he could face new ecclesiastical penalties, including the possibility of excommunication.
On the other hand, the Vatican's decision to laicize Pavone is not believed to have affected his role as board chairman and director at Priests for Life.
In its statement to U.S. bishops, the Dicastery for Clergy noted that “since Priests for Life, Inc. is not a Catholic organization, Mr Pavone’s continuing role in it as a lay person would be entirely up to the leadership of that organization.”
On Dec. 19, Pavone tweeted that “my board, pastoral team & staff are 1000% united with me in moving forward with our work. We will not slow down. My vocation is to be a priest and a #prolife leader and I will not walk away from either one of those!”
The page listing the board members of Priests for Life returns an error message at Priests for Life’s website. But a version of the page archived in June lists one priest and seven lay people as board members of the organization.
Pavone has also received a number of public expressions of support from political commentators and online Catholic activists — and from Catholics who say Pavone’s laicization was political.
Most notably, the Bishop of Tyler, Texas, publicly took issue with the Vatican’s ruling.
Bishop Joseph Strickland said on Twitter that “The blasphemy is that this holy priest is canceled while an evil president promotes the denial of truth & the murder of the unborn at every turn.”
“Vatican officials promote immorality & denial of the deposit of faith & priests promote gender confusion devastating lives…evil,” Strickland wrote.
The bishop’s comments have proven controversial, as seemed to call “blasphemy” the decision to “cancel” - or laicize - Pavone, which was officially an act of Pope Francis.
Some critics of Strickland’s statement have mentioned canon 1373, which states that “A person who publicly incites hatred or animosity against the Apostolic See… because of some act of ecclesiastical office or duty, or who provokes disobedience against them, is to be punished by interdict or other just penalties.”
Supporters, on the other hand, have argued that Strickland's tweet wasn’t intended to criticize Pavone’s laicization, only the handling of other issues in the Church, including advocacy for legal protection of abortion from President Joe Biden.
As of Dec. 19, Strickland has not offered any public qualification of his statement.
For their parts, neither the Diocese of Amarillo, where Pavone was incardinated, nor the Diocese of Orlando, where he resides, have released statements regarding Pavone.
This explainer was updated Dec. 20 to address the question of Pavone's notification of the laicization.