I am an attorney. While I do not undertake capital defense work, one truth of that practice area applies to averting the closure of a Catholic church/parish: “the easiest way to keep your client from being executed is to ensure they don’t end up on death row to begin with.” While you may be angry that your local ordinary ordered your parish and/or church to permanently close, you cannot allow this anger to preclude you from attempting to reach a compromise which will avert the need to “fight” for your parish/church’s survival. While I will discuss how to use canon law to appeal against the closure of your parish and/or church, I will say now that if such fights can be avoided, everyone wins. Fights over the fate of parishes and churches become extremely emotional very quickly and have a tendency to degenerate into mutual grudge-matches, with both church leaders and the laity frequently engaging in conduct which to put it bluntly is often anything but Christ-like. Even if a canonical appeal is successful, the victory does not automatically result in the restoration of the previous level of liturgical activity at your parish or church. Thus, if a settlement that can give you the most you are entitled to under canon law can be reached without the need for an appeal to be filed, you should always move in this direction.

     Given that ordinaries have wide latitude to eliminate parishes for just causes, there is little in the way of leverage a lay person has to compel a bishop or archbishop who is determined to eliminate a particular parish to change course. This is all the more so the case for a parish which is running a deficit, which has a purely aging membership (one where few or no children are parishioners,) or one established to serve a particular ethnic group where mass in the language which was originally spoken by the parishioners is no longer said (such as in the case of a Lithuanian personal parish where mass is no longer celebrated in Lithuanian.) If a parish is flush with cash and has a membership with a healthy number of children and young people, these facts can and should be pointed out to an ordinary. At the end of the day if he is committed to the parish’s elimination however, nothing aside from an appeal with in my opinion long odds of success will prevent the parish’s elimination.

     When it comes to the relegation of churches to profane but not sordid use however, it is a potentially different story. Ordinaries have less latitude to permanently close churches, as their closure requires the presence as was mentioned earlier of a canonically “grave” cause. While an ordinary can eliminate parishes fairly easily, without the presence of a cause of sufficient gravity, he cannot validly decide to eliminate a specific church without the presence of a grave cause. This is not to say that a bishop or archbishop won’t attempt to do this; I am sadly all too well aware of various ordinaries who for reasons known only to them are bent upon the relegation of seemingly all former parish churches not regularly used in their dioceses and archdioceses and at the same time committed to fighting any and all efforts to ensure that they are retained as Roman Catholic sacred spaces at no expense to the dioceses/archdioceses and parishes in which they are located.

     Leaving aside those instances when ordinaries are determined to close churches, the provisions of canon law notwithstanding, it is often the case, as hard as it may be for some lay people to believe, that diocesan and archdiocesan leaders are not aware of available options which can make the relegation of a church to profane but not sordid use unnecessary and canonically impossible. For readers outside of the United States, the knowledge that Roman Catholic churches exist in capacities other than “parish churches” is not terribly earth shattering. It is common place in Europe and many other parts of the world to see churches purpose built to serve as shrines or chapels, i.e. churches never intended to serve as the seats of parishes. Likewise, the idea that entities other than dioceses and parishes can own churches is not one which is all that surprising to those who have lived among purpose built non-parish churches throughout the entirety of their lives. For a person who passes the church built specifically for the use of the Dominicans and owned outright by the religious order or the chapel owned by the guild of cobblers on their way to the café in the morning day in and day out, little in the way of convincing is necessary to cause them to understand that such ownership and use arrangements for churches are possible.

     In countries such as those which make up Western Europe where churches owned by religious orders and various associations of Catholics are common, Catholicism has been the faith of the majority of the population for many centuries. The preeminent place the Catholic Church has held in these societies has permitted church ownership and usage to develop and flourish in all of its various canonically possible forms, with little difficulty aside from various instances of monarchs or revolutionary governments attacking the church to satisfy ideological grudges or a thirst for monetary gain (i.e. the French Revolutionary regime of 1792, Otto Von Bismarck, Holy Roman Emperor Joseph II, etc.)

     The United States however did not form as a Catholic nation. Toleration and the eventual free practice of Catholicism did not fully emerge in most of the lands which came to make up the United States until many decades after initial European colonization accept in those parts of the nation originally colonized by France and Spain. Thus, while various religious orders came to own some property, the vast majority of Catholic property in the United States came to be owned by dioceses/archdioceses and parishes. This practice arose on account of the fact that the organization and spread of the Catholic faith in the United States came about through the establishment of new dioceses and parishes in territories where Catholics had settled and thus required access to the sacraments of the church. Rather than naturally developing as new religious communities arose, the Roman Catholic Church in the U.S. grew as parishes arose in specific areas to meet the needs of the faithful who settled within them.

     Based on the research I’ve undertaken, I am forced to conclude that little thought seems to have been given to the sacred nature of Roman Catholic churches as the church grew throughout the United States. This is not surprising; until recent decades the churches which had been constructed throughout the nation were filled with faithfully practicing Catholics. The fact that until the revision of the Code of Canon Law which took place in 1983, no means existed for the valid permanent closure (relegation to profane but not sordid use) of a Roman Catholic Church unless it had been damaged beyond the point of being able to be repaired also likely led most members of the clergy to pay little mind to the canonical state of the churches in which they ministered. This lack of study in the United States and other nations in which Catholics did not initially form the majority of religious adherents of alternative ownership arrangements for churches following the merging of parishes which would allow them to remain Roman Catholic sacred spaces (in accordance with the definition of Canon 1214 of the Code of Canon Law of 1983) means that when this information is presented to ordinaries and others in positions of diocesan and archdiocesan leadership, it may be the first time they are being exposed to it. For better or worse, this is just the state of things.

     In the event that a decision is made to eliminate your parish and/or your church, the immediate actions you need to take depend on whether a “DECREE” (a formal canonical order) to implement the closure decision has been issued. If it has, in addition to attempting to settle the case, you need to file a “petition for hierarchical recourse,” the canonical name for appealing a closure decision (this is discussed in the next section of this article.) Regardless of whether a canonical appeal is necessary, any Catholic challenging the closure of a parish or church needs to present a plan FIRMLY GROUNDED IN CANON LAW (this point is essential; merely presenting your grievances against a closure decision is not sufficient) to the ordinary who determined the closure was warranted. In the case of a parish, as mentioned above, presenting statistical information illustrating why it is that the parish targeted for closure is still needed to sustain the Catholic faith in the community in which it exists is the only course of action which MIGHT lead to the decision to eliminate the parish being reversed. With regard to plans which would allow for the permanent closure of a church to be averted, there are a number of solutions which could be presented to an ordinary. Determining which option(s) you should propose as an alternative to the closure of your church is a decision which must be made strictly based on the specific circumstances associated with the church which is being proposed for closure.

     The alternatives to the permanent closure and sale for non-Catholic purposes of a Roman Catholic church being targeted for closure fall into three broad categories, entrusting the church’s care to a religious order, transferring it to another “rite” of the Catholic church for use by faithful of that ritual church, and transfer of the church to the care of a group of lay Catholics (not confined to former “parishioners” of the church in question) which would assume complete responsibility for the care and maintenance of the church. At the outset, those seeking to avert the permanent closure of a Roman Catholic church must understand that when determining which of these options they present to a diocesan or archdiocesan ordinary in an effort to persuade him to reverse his closure decision that they must make this determination with complete objectivity, that is, without showing any partiality toward a particular option stemming from their personal preference. Conditions associated with each church facing permanent closure, such as the size and condition of the church, the number of people interested in ensuring that it remains a Roman Catholic sacred space and the financial resources they have to make this possible, the availability of religious orders who could step in to care for the church and the openness of the ordinary within whose jurisdiction the church lies to allow them to step in for this purpose, and the presence or lack thereof of Catholics from other “rites” of the church aside from the “Roman” or “Latin” rite who need a place of worship in which their faith can be practiced must be the criteria upon which a determination is made of which alternatives are presented to an ordinary. At this point I will describe in broad terms each of these alternatives to the relegation of a church to profane but not sordid use.

     Religious orders, Canonically classified as both “Institutes of Consecrated Life” and “Societies of Apostolic Life” have the right to own churches for the use of the members of their religious congregation. There are far more religious orders in existence than most lay Catholics are aware of. It is likely that most have heard of the Franciscans (though there are a large number of different Franciscan congregations,) Benedictines, Carmelites, Dominicans, and Jesuits. Others though such as the Claretians, Viatorians, Edmundites, Norbertines, Institute of Christ the King Sovereign Priest and Fraternity of St. Peter may not be as well-known owing to either their smaller sizes or their specific ministries. Regardless of the exact canonical structure of each order, each can, if it wishes, with the permission of a local ordinary, assume responsibility for and ownership of a former Roman Catholic parish church.

     Several IMPORTANT POINTS must be kept in mind when determining whether the option of turning a church’s care and maintenance over to a religious order should be presented to an ordinary. First and foremost, those proposing this option must have a firm commitment from a religious order that it is prepared to assume complete responsibility for and potentially ownership of the church in question. Merely proposing that a religious order might want to take full responsibility for a church without a concrete commitment from one that it is willing to do this is NOT SUFFICIENT. A religious order’s willingness to take responsibility for the complete care and maintenance of a former parish church is itself not enough to allow such a plan to be implemented. The activities of all religious orders within a diocese or archdiocese, including their entry into a particular diocese or archdiocese are subject to the permission of the local ordinary within whose territory they would be residing and operating. Thus, the ordinary within whose territory the church being targeted for closure lies must give his permission for a particular religious order which is willing to take on the responsibility of caring for and maintaining the church to begin doing so. Only following the receipt of this permission is it possible for a religious order to step in and take responsibility for a church.

     In addition to the potential unwillingness of an ordinary to entrust a church he is targeting for closure to a religious order, many religious orders are presently trying to free themselves from as many commitments as possible. They often are also trying to liquidate the properties they already own, owing to the decreases in membership they have experienced in the last several decades and the increase in age of those members of their congregations who remain. These challenges make it unlikely that a religious order is going to wish to take responsibility for the care and maintenance of a former parish church unless the church will specifically aid them in advancing their ministry. Examples of instances when taking full responsibility for a former parish church might be appealing to a religious order include when the order would be able to gain custody of other structures such as a former rectory or convent along with the church. These additional structures could provide an order with space to house its members or carry out its ministry in a community. Even when offered former parish rectories or convents however, religious orders often decline to take custody of former parish churches, as they feel their care and upkeep will detract from their ability to provide ministerial support to the community in which it is located. If a local ordinary has invited a religious order such as the Institute of Christ the King or the Fraternity of St. Peter into his diocese or archdiocese to provide those seeking to attend the celebration of the Tridentine (Latin) mass, it may be the case that a former parish church could serve as a location for these masses and as a base of operations for an order invited into a diocese or archdiocese to provide them. Orders established to provide for the celebration of the Tridentine mass are not large enough to take on the care of all of those churches facing closure. While a religious order taking custody of a former parish church can provide for its future as a Roman Catholic sacred space, it is not always possible to find an order willing to do this or to gain the permission of church leaders for it to occur even when an order is willing to step in.

     The Roman or “Latin” “Rite” of the Catholic Church is only one of the 24 Catholic “Rites” which make up the universal Catholic Church. While the Latin Rite of the Catholic Church contains the vast majority of the Catholic faithful, nearly two dozen other “Rites” of the Catholic faith, each with their own liturgical traditions  exist, generally made up of members from specific geographic areas. For instance, the Syro-Malabar and Syro-Malankara Rites of the Catholic Church originated in India and have spread throughout the world as their adherents have migrated. Similarly, members of the Maronite Rite of the Catholic Church have moved from Lebanon where the rite originates to many other parts of the globe in recent decades. Eastern Rites of the Catholic Church have their own hierarchical structure, i.e. the faithful and clergy of each Rite are  subject to the leadership of the Rite in a geographic area and not a Latin Rite diocese or archdiocese (unless so few of the faithful reside in an area where Latin Rite Catholics predominate that the local diocese or archdiocese has been given responsibility for directly arranging for the provision of liturgical services for those faithful of a particular Eastern Rite of the Catholic Church who reside within its boundaries.)

     Knowledge of Eastern Rite Catholicism and those faithful who practice it has been growing in the United States in recent years as Eastern Rite Catholics have migrated there in ever greater numbers both in search of economic opportunities and to escape conflict or political persecution in their homelands. As those adhering to various Eastern Rites of the Catholic faith have been increasing in number, the question of where these Catholics can practice their faith has often arisen. In those locations where an increase in the number of Eastern Rite Catholics has coincided with a diocese or archdiocese’s decision to eliminate parishes and churches, it has been possible to avoid the permanent closure of a number of churches through their being turned over to Eastern Rite congregations in need of a place of worship.

     While some Latin Rite Catholics who have called a particular Roman Catholic Church home for many years may be saddened at the thought of an Eastern Rite Catholic Congregation with different liturgical practices gaining custody of the church, in all honesty this outcome should not be lamented. Unlike Protestant congregations and those of the Orthodox Christian Church, Eastern Rite Catholics are just as Catholic as Roman Catholics. They are in communion with Rome and it is perfectly acceptable for a Roman Catholic to satisfy their Sunday mass obligation by attending an Eastern Rite Catholic liturgy (switching Rites and formally becoming an Eastern Rite Catholic is far harder.) Transfer of a church used by Roman Catholics to an Eastern Rite Congregation does not see the church relegated to profane but not sordid use; in such a situation, filing a canonical appeal against this type of transfer is not even possible. If it should be the case that a growing number of Eastern Rite Catholics in a particular area is in need of a permanent place of worship and it is objectively the case that the number of Latin Rite Catholics upset about the planned closure of a Roman Catholic church is small and not likely to grow, encouraging the transfer of the church into Eastern Catholic hands may make the most sense in terms of securing the future of the church as a Catholic (even if not Roman Catholic) sacred space. While the number of Eastern Rite Catholics in the United States has been increasing in recent years, the number of Eastern Rite faithful in the country is still relatively small. Thus, it may not be the case that enough Eastern Rite faithful reside sufficiently close to a threatened Roman Catholic church to make transfer of the church to an Eastern Rite congregation a realistic possibility. If Eastern Rite Catholics are searching for a permanent liturgical home however and a threatened church used by Roman Catholics is available, entrusting the church to a new Eastern Rite congregation may be the most sensible alternative to permanent closure those seeking to save the church can propose to an ordinary preparing for its elimination.

     Finally, in those instances where no religious order or congregation of Eastern Rite Catholics is able or willing to take on the complete responsibility of caring for and maintaining a former Roman Catholic parish church in order that it can remain a Roman Catholic sacred space, it is possible for lay Catholics committed to retaining the church for this purpose to step in. This can occur in several different ways. Just as canon law makes it possible for religious orders to come into being and gain the ability to validly own churches, so too does it give this ability to lay Catholics, such as those who are organized as “associations of the Christian faithful.” There are two types of associations of the Christian faithful, those which are “public” and those which are “private.” The most straightforward way to distinguish between the two types of associations is to understand that while both exist to further the ministerial objectives of the Roman Catholic Church, they accomplish this in different ways. Public associations of the Christian faithful are usually formed by church leaders to further particular goals they wish to advance; the associations often are closely tied to the church leaders overseeing their formation and work. Private associations of the Christian faithful meanwhile generally are formed without explicit direction from church leaders by groups of lay Catholics who wish to come together to accomplish a specific purpose which will further the church’s mission on earth. While public associations of the Christian faithful are endowed with “juridic personality,” a canonical designation similar to that enjoyed by corporations under civil law as an automatic consequence of their formation (just as is the case with religious orders, parishes and dioceses,) private associations of the Christian faithful must petition the ordinary of the jurisdiction in which they form and ask to be granted juridic personality before it can be conferred upon them. It is also the case that only public associations of the Christian faithful have the right to teach the doctrine of the Roman Catholic Church.

     As the frequency with which churches are being relegated to profane but not sordid use has increased, so too has it become more common for their care and ownership to be transferred to private associations of the Christian faithful. Catholics wishing to avert the permanent closure of a Roman Catholic church can come together and form a private association of the Christian faithful, with the objective of retaining the threatened church in order that it can continue to exist as a Roman Catholic sacred space, available for such things as private prayer, the recitation of the rosary and other approved Catholic devotional prayers and the celebration of such occasional masses as the local ordinary and canon law permit to be celebrated within it. Given that churches in the words of the Congregation for the Clergy must retain their sacred character “if at all possible,” turning their care, maintenance and ownership over to a properly constituted private association of the Christian faithful can serve as a means of ensuring that a church beloved by Catholics is not unnecessarily closed forever and that it remains able through its existence to serve as a tool of evangelization in the location where it stands and in points beyond.

     In order for a private association of the Christian faithful to gain custody and ownership of a church which has served as a place of Roman Catholic worship, the group will first need to form in the diocese or archdiocese in which the church is located and gain recognition by the ordinary of that jurisdiction. Recognition by the diocesan or archdiocesan ordinary won’t be possible until the association has drafted a set of canonical “statutes” and separately a set of canonical “bylaws” which will regulate its activities and relationship with the ordinary and the jurisdiction in question and the universal Roman Catholic Church; these statutes and bylaws must also be approved by the ordinary. Once the ordinary recognizes the association and approves its statutes and bylaws, erecting the group as a private association of the Christian faithful, he then must grant it “juridic personality” to endow it with the right to own sacred goods, including the church it wishes to care for. In addition to all of these steps, specifics as to the agreement transferring the church and potentially other property associated with it to the association must also be worked out, including the civil arrangements under which these transfers take place. It is possible that a reversionary clause may be included in any deed of transfer, ensuring that if the association failed in its mission to care for and maintain the church that the diocese or archdiocese in which it is located would be able to regain the property without the risk that it would be sold on the open market.

     If it is the case that the leaders of a diocese/archdiocese do not wish to go through the steps necessary to establish an association of the Christian faithful to take custody of a former Roman Catholic parish church, it is also possible for lay Catholics to take ownership of such a church through alternative means without the church being permanently closed. If a group of Catholics comes together for this specific purpose, they can form a nonprofit corporation in the U.S. state in which the church is located to assume ownership of the church as a Roman Catholic sacred space, in order that they can continue to pay all of the costs associated with its continued existence as such. This corporation can then apply to the Internal Revenue Service (IRS) for federal tax-exempt status under section 501 C (3) of the federal tax code, so that all donations to the group will be federally tax-exempt. All of these steps mirror the actions a group of Catholics seeking to form an association of the Christian faithful will need to take civilly prior to such an association being canonically formed. Under this alternative arrangement however, the relationship of the nonprofit corporation which will own and care for the church and the diocese/archdiocese in which it is located is defined by a memorandum of understanding signed by both the Catholics leading the nonprofit and the ordinary or his designee of the diocese/archdiocese in which the church is located. This memorandum of understanding spells out which liturgical celebrations (if any) aside from the canonically required two masses which must be said yearly within all churches the ordinary will permit, and all other requirements which must be observed to ensure the church remains a Roman Catholic sacred space.

     If no lay Catholics are present locally to form a group to maintain an unneeded church as a Roman Catholic sacred space and no other options for this outcome exist, the St. Stephen Protomartyr Project, a nonprofit organization based in Massachusetts of which I am the president may be able to step in to ensure a church is not lost. In addition to providing assistance to Catholics seeking to avert the permanent closure of their churches, the St. Stephen Protomartyr Project with the cooperation of a diocese/archdiocese can step in to take ownership of and responsibility for a church which would otherwise be permanently closed, as our mission includes taking this step when it is necessary. Decisions as to which churches the St. Stephen Protomartyr Project could take ownership of and responsibility for are made based on the organization’s budgetary capacity and such other things as the sacred art/architecture contained within the church, the age of the church and whether the church in question has a connection to Catholics of note (such as a beatified or canonized person) or an event of note in Catholic history. Just as is the case with religious orders, the activities of associations of the Christian faithful and all lay groups which own/are responsible for Roman Catholic churches must be overseen by the leadership of the Catholic Church. It would be improper for a group to gain custody and ownership of a Roman Catholic Church and then knowingly or unknowingly subject it to some form of liturgical abuse.

     Private associations of the Christian faithful and other lay Catholic organizations which can validly own Roman Catholic churches which remain Catholic sacred spaces are not means of gaining independence from the Roman Catholic Church and must not be seen as such. While ownership of a church can be transferred from a diocese or archdiocese which no longer wishes to be responsible for its care and upkeep to such groups, this does not give them the right to do whatever they wish with the churches. They CANNOT FOR INSTANCE employ a priest of their choosing in order that mass can be celebrated within the churches they are responsible for at any time they wish mass to be said. The rules concerning when mass can be celebrated within all churches, along with the canonical designation each church holds (shrine, chapel or oratory) are determined by the ordinary of the jurisdiction in which the church is located. Those seeking to form an association of the Christian faithful or another lay group to take on the care and upkeep of a Roman Catholic Church must understand that an exceedingly large amount of trust must exist in order for these arrangements to work between the ordinary entrusting the church to the group’s care and the faithful who wish to work above and beyond their duty as Catholic parishioners of whichever parish they belong to in order that a church they care about may remain a Roman Catholic sacred space. To this end, a private association of the Christian faithful or other lay group must not attempt to “push the envelope” and in any way assume a confrontational posture with regard to the leadership of the diocese or archdiocese with which it is seeking to make an agreement, if those church officials with whom they are dealing are properly following canon law.

     Before attempting to form an association of the Christian faithful or other lay group to take ownership of and provide care for an unneeded church, those seeking to do so need to honestly ask themselves whether they have enough support, both through the participation of likeminded Catholics and in terms of financial resources to ensure that the group will have the long-term support it needs to maintain the church it wishes to care for in a state of good repair. Just as a problematic relationship between a private association of the Christian faithful or other lay group and a diocese/archdiocese will negatively impact the ability of other Catholics to step forward in the future and seek to enter into similar agreements to ensure the future of other former Roman Catholic parish churches which may face permanent closure in that jurisdiction, so too will it be harder for Catholics to step forward and do this if it should be the case that the diocese or archdiocese in question approved such an agreement in the past, only to see the group fall apart or be otherwise financially unable to care for the church it stepped forward to protect. While the desire to save a Roman Catholic church from being relegated to profane but not sordid use is an admirable one which is to be commended, it cannot be the case that actions such as the formation of a group to make this possible can be taken lightly, with the consequence being that they fail on account of a lack of planning.

     Finally, if it is the case that an ordinary is uncomfortable with any of the other plans discussed above which when properly executed would avert the need for a church’s relegation to profane but not sordid use, a group of Catholics could offer to take complete financial responsibility for the continued upkeep and maintenance of the church without assuming ownership of the structure. Such an arrangement would function similarly to that under which a church would be deeded over to a private association of the Christian faithful or other group of lay Catholics. The group of Catholics, likely organized civilly as a nonprofit corporation with federal tax exemption would agree to cover all of the costs associated with the church’s continued care and upkeep. In exchange, the church would not be relegated to profane but not sordid use, remaining available for private Catholic prayer and devotional activity as well as for the celebration of occasional masses. The frequency with which mass would be celebrated in the church would be determined by agreement between the group caring for the church and the diocese/archdiocese in which it is located.

     An agreement without the transfer of the deed of a church would likely take the form of a lease entered into between the group which would be caring for the church and the diocese/archdiocese which owns it. Any agreement of this type should not require the group taking responsibility for the church to pay more than $1 per year (the group is already doing the diocese/archdiocese in which the church is located a favor by maintaining the church at its own expense; asking it to pay more on top of that is unacceptable.) While such an arrangement is the most unstable of all potential arrangements under which a church could avoid relegation to profane but not sordid use, owing to the deed for the church not being in the hands of the group responsible for it, the fact that Catholics are paying all of the costs associated with maintaining a church will prevent the diocese or archdiocese which owns it from being able to claim a cause of sufficient gravity to justify the church’s relegation to profane but not sordid use. Under any arrangement where a group is established to pay the costs associated with the care and upkeep of a Roman Catholic church to avert its relegation to profane but not sordid use, all receipts illustrating the expenses they have incurred in this regard should be retained in case it should become necessary in the future to illustrate the group’s activities in support of the church, such as during potential future canonical litigation if an attempt is made to relegate the church to profane but not sordid use in spite of it being properly cared for by the group to whom it was entrusted. Unfortunately, some ordinaries have attempted to relegate churches to profane but not sordid use which they still own for reasons known only to them after tens of thousands of dollars in restoration work has been contributed by the group caring for it which would seemingly make the taking of this step impossible. The potential instability of these arrangements make them in my opinion the least desirable for guaranteeing the future of a church as a Catholic sacred space.

     Regardless of the type of canonically valid arrangement which may be entered into that would avert the relegation of a church to profane but not sordid use, it is always preferable to enter into such an arrangement if this is possible in order that canonical litigation associated with a parish’s or church’s future status may be avoided. While it is far harder to convince an ordinary to change his mind concerning the closure of a parish, owing to the extremely limited protections parishes enjoy under canon law compared to those which exist for churches, attempts should be made by those seeking to avert the closure of a parish, a church or both to settle these matters, either prior to the need arising to file an appeal against a canonical decree issued to formally bring about the closures or in conjunction with the filing of such appeal(s). Lay Catholics attempting to settle these matters should keep in mind that the most important objective should always be the retention of the church in question as a Catholic sacred space, not relegated to profane but not sordid use. Regardless of which Catholics utilize it most frequently, ensuring that a Catholic church is not given over to non-Catholic sacred use is one of the most important actions a lay Catholic man or woman can take. Thus, concerns about the number of masses which can be celebrated within the church on an annual basis and the exact path the ordinary in question wishes to take to ensure the church remains a Catholic sacred space in perpetuity should not be quibbled over. So long as it is the case that a diocese or archdiocese is following canon law or is willing to if it is made aware that a proposed course of action on its part violates a provision of the code, those advocating for the continued existence of a church as a Catholic sacred space should do all in their power to be cooperative in terms of seeing the plan through to completion.      This being said, when a diocese/archdiocese pins a church’s continued existence solely on how much a given parish may raise without taking into consideration the fact that parish funds ARE NOT the only source of financial support which can guarantee a church’s retention as a Catholic sacred space, this is generally a plan to lay the groundwork for the future closure of the church. If it is the case that this type of agreement is the only type of agreement a parish, diocese or archdiocese which is planning to relegate a church to profane but not sordid use is willing to make even after being made aware that canon law makes clear that external sources of funding must be permitted to support the continued existence of a church as a Catholic sacred space, it is likely the case that canonical litigation concerning the church’s future is going to be necessary.