Phyllis Konchar worked as a principal at St. Joseph’s Catholic School for nineteen years. The School was overseen by Father Pins, who was appointed by the Bishop for the Diocese. Despite efforts between both Konchar and Father Pins to resolve their differences in a professional manner, Konchar’s employment was terminated for cause on March 9, 2018. Konchar filed suit against Father Pins, St. Joseph’s Church, and the Diocese of Des Moines, primarily for defamation. The claims were based on the following statements made as part of emails and press releases related to her termination:
“We concluded that there was a pattern of conduct that warranted choosing not to renew Ms. Konchar’s contact.” – Father Pins, March 11, 2018
“Please be advised that the prior two pastors were consulted and Bishop Pates approved the decision following the evaluation of the past conduct.” – Father Pins, March 11, 2018
“The outcome of the investigation pointed to serious irregularities in the school administration under her direction.” – Diocese of Des Moines, March 12, 2018
The district court granted summary judgment as to the claim that she had been defamed by the statements in Father Pin’s March 11, 2018 email. The court denied summary judgment on the comments “there was a pattern of conduct” and “serious irregularities in the school administration.” The case went to trial on those two defamation claims, and the jury returned a defense verdict. Konchar appealed to the Supreme Court, in part, regarding the dismissed alleged defamatory comment “two pastors were consulted and … approved the decision.”
The Supreme Court ruled that the court properly dismissed the “two pastors” defamation claim, stating “there can be no defamation without a false statement.” And substantial truth is an established defense to a defamation claim. Yates v. Iowa W. Racing Ass’n, 721 N.W.2d 762, 769 (Iowa 2006). Konchar’s claim depended solely on whether Father Pins “consulted” with “two pastors.” Because it was undisputed that Father Pins did consult with the two prior pastors about Konchar, her claims failed under the substantial-truth doctrine. Konchar argued that her claim wasn’t about whether he had consulted two pastors, but whether the statement falsely implied that the two pastors approved of her 2018 firing. The Court determined that her defamation claim hinged on whether a Catholic priest was justified in determining she should no longer serve as principal at a Catholic school. However, the district court and Supreme Court concluded that an inquiry into that question would run afoul of the First Amendment’s Free Exercise Clause. Konchar’s three defamation claims were unsuccessful.
Phyllis Konchar v. Joseph Pins, St. Joseph’s Church of Des Moines, and the Roman Catholic Diocese of Des Moines, No. 21-1275 (Iowa April 14, 2023).