Adorers of the Blood of Christ v. Federal Energy Regulatory Commission

The Third Circuit Court of Appeals affirmed the dismissal of a lawsuit filed in district court in Pennsylvania by a vowed religious order of Roman Catholic women who challenged the Federal Energy Regulatory Commission’s (FERC’s) authorization of a 200-mile natural gas pipeline that would cross the order’s property. The religious order—Adorers of the Blood of Christ (Adorers)—contended that use of their land as part of the project violated their rights under the Religious Freedom Restoration Act. The Third Circuit noted that the Adorers “followed an encyclical letter titled ‘Laudato Si’ of the Holy Father Francis on Care for our Common Home,’ written by Pope Francis” that “provides a comprehensive theological basis that, as an act of religious belief and practice, members of the Roman Catholic Church must preserve the Earth as God’s creation.” The encyclical specifically mentioned climate change as a global problem. In their lawsuit, the Adorers alleged that natural gas development would contribute to global warming in a manner contrary to their religious beliefs. The Third Circuit found that the district court did not err in concluding that it lacked subject matter jurisdiction because the Adorers had failed to raised their claim using the procedures required by the Natural Gas Act for challenges to FERC actions.