2 September 2010
Canons commonly cited
All translations from the Canon Law Society of America, 1999.
1983 CIC 1364. § 1. Without prejudice to the prescript of can. 194, § 1, n. 2, an apostate from the faith, a heretic, or a schismatic incurs a latae sententiae excommunication; in addition, a cleric can be punished with the penalties mentioned in can. 1336, § 1, nn. 1, 2, and 3. § 2. If contumacy of long duration or the gravity of scandal demands it, other penalties can be added, including dismissal from the clerical state.
1983 CIC 1367. A person who throws away the consecrated species or takes or retains them for a sacrilegious purpose incurs latae sententiae excommunication reserved to the Apostolic See; moreover, a cleric can be punished with another penalty, not excluding dismissal from the clerical state.
1983 CIC 1382. A bishop who consecrates someone a bishop without a pontifical mandate and the person who receives the consecration from him incur a latae sententiae excommunication reserved to the Apostolic See.
1983 CIC 1398. A person who procures a completed abortion incurs a latae sententiae excommunication.
I have found no verification that any of the following persons were or are formally excommunicated:Tom Cruise (America, apostasy); George Harrison (England, apostasy) Madonna (America, apostasy); Sinead O'Connor (Ireland, ordination).
Occasionally, one runs across stories of parish priests threatening or pronouncing excommunications. Such actions are wholly outside of canon law, and will not be recorded here.
Other items of note
Canon Law Excommunication Blotter
On 11 June 2009, Fr. Luciano Mbewe was declared excommunicated by CDF, for schism (c. 1364), for his role in founding the Catholic Apostolic National Church of Zambia. See allAfrica.com. Some 20 Ugandan priests joined Mbewe in forming the "Catholic Apostolic National Church in Uganda" in January 2010. See Catholic News Agency.
On 8 May 2009, it was announced that Chris Carpenter, a priest of the Diocese of Phoenix, was excommunicated within the previous month by decree of Bp. Thomas Olmstead. No canons were cited, but Carpenter's public statement show him rejecting Church teaching on the 'ordination' of women. See: Catholic On-line US News.
Archbishop Jose Cardoso Sobrinho of
Olinda e Recife declared the excommunication of doctors and other direct
participants in an abortion performed against the unborn baby of nine-year-old
rape/incest victim. Presumably the canons invoked were
1983 CIC 1398 and
1983 CIC 1329. The mother of the baby
was not excommunicated; her age alone would have been sufficient to prevent her
incurring any penalty (1983
CIC 1323). See
FoxNews.com, 5 March 2009.
On 15 December 2008, the Diocese of Phoenix announced that Bp. Thomas Olmsted had declared excommunication against Monsignor Dale Fushek and the Rev. Mark Dippre, apparently for schism. East Valley Tribune; Diocese of Phoenix website.
On 19 November 2008, CNS reported that Francis Cdl. George of Chicago thought it possible that Catholic politicians who might support FOCA act would be liable to excommunication. He was joined in this opinion by Deal Hudson. See AmericanPapist, 21 November 2008. I believe this position is mistaken and set forth the options I see for canonical response to Catholic support of FOCA here.
On 4 November 2008, Archbishop Nicolas Cotugno of Montevideo told the Uruguayan daily El Pais that lawmakers who vote in favor of the legalization of abortion incur automatic excommunication. Catholic news Agency. The prelate offered no canonical support for his conclusion.
On 9 August 2008, Janice Sevre-Duszynska received pseudo-ordination by Womenpriests in the Diocese of Lexington KY. She is subject to the established latae sententiae excommunication.
On 20 July 2008, four women claimed to have received holy orders in Boston. Presiding over the ceremony were Dana Reynolds and Ida Raming of RC Womenpriests. Claiming priesthood were Gloria Carpento (Baltimore), Judy Lee (Ft. Myers), Gabriella Velardi Ward (New York), and Mary Ann McCarthy Schoettly (Newton NJ) claimed diaconate. The women then simulated the Eucharist. The Archdiocese of Boston reiterated the latae sententiae excommunication in place against such acts. Boston.com. A survey article by Sandro Magister.
On 30 May 2008, CDF announced that those attempting to confer holy Orders on women, and the women attempting to receive holy Orders, hence forth incur automatic excommunication. The sanction was linked to 1983 CIC 1378. Canonical analysis In Light of the Law, 30 May 2008.
On 14 March 2008 Abp. Raymond Burke of St. Louis declared latae sententiae excommunications against two lay persons (Rozanski and Krauze) for schism under 1983 CIC 1364. These persons had, despite warnings, joined the Board of St. Stanislaus Corporation, a suppressed parish of the archdiocese.
On 12 March 2008, Abp. Raymond Burke of St. Louis excommunicated three women (Fresen, Hudson, and McGrath) for conferring and receiving pseudo-ordination, specifically an act of schism under 1983 CIC 1364. All three women were also placed under interdict for pertinacious rejection of Catholic doctrine (specifically Ordinatio sacerdotalis) in accord with 1983 CIC 1371, n.1. Fresen was also excommunicated for simulation of a sacrament under 1983 CIC 1379. See Light of the Law, 14 March 2008.
On 28 January 2008, Archbishop Jose Cardoso Sobrinho condemned a plan by Recife (Brazil) city officials to distribute the "morning-after pill" and warned that those who use the pill are subject to excommunication. "This policy is wicked and immoral, and in this case, both those who use it and those who incite its use are committing a crime punishable by excommunication," Archbishop Cardoso said. LifeSite News. Light of the Law, 30 January 2008.
On 21 January 2008, Archbishop Andreas Choi Chang-mou of Kwangju (South Korea) declared Julia Youn and her followers to have incurred latae sententiae excommunication under 1983 CIC 1364 and, allegedly 1331 (sic?). The case is incompletely reported, but apparently it deals with unapproved "miraculous" events, an unauthorized Marian shrine, and acts of schism and agitation of followers against episcopal authority. Warning of excommunication seem to go back some years, and at least one priest, Aloysius Chang Hong-bin, was excommunicated and deprived of faculties. Decree of the Archbishop of Kwangju, 21 January 2008; 21 January 2008; Mirifica News, 5 February 2008; Boston Pilot, 25 January 2008.
Despite a public warning of automatic excommunication from Abp. Raymond Burke (on 9 Nov 2007), Rose Marie Dunn Hudson of Festus and Elsie Hainz McGrath of St. Louis purported to receive (presumably diaconal and) presbyteral ordination on Sunday, Nov 11, in the territory of the archdiocese of St. Louis. On or about Nov 12, the two women were cited to appear before the tribunal of the archdiocese on Dec 3.
On 7 October 2007, Rev. Charles Apestéguy, (incardinated in Italy but serving in Montreal) received episcopal ordination from a bishop of the Utrecht Union, in violation of 1983 CIC 1382. The Apostolic Nuncio of Canada announced the declaration of excommunication that had been issued by Bp. Gio Reali of Porto Santa Rufina. See Newsletter of the Canadian Canon Law Society (2007, n.2) at 22. (nb: some have suggested the ordaining bishop might be from a break-away group from the UR.) The excommunication against Fr. Apestéguy was remitted con atto di peculiare clemenza by the Congregation for the Doctrine of the Faith on 10 December 2008.
On 21 September 2007, Bishop Arturo Bastes of Diocese of Sorsogon (The Philippines) declared a latae sententiae excommunication against Fr. Alejandre V. Galias for violating the seal of confession (1983 CIC 1388). Fr. Galias is appealing (or taking recourse, it is not clear which) against his excommunication. By operation of 1983 CIC 1353, appeal or recourse against a penalty suspends its effects. 18 October 2007.
On 14 September 2007, the Canadian Conference of Catholic Bishops announced that, on 11 July 2007, the Congregation for the Doctrine of the Faith had declared excommunications under 1983 CIC 1364, specifically for heresy and schism, to have been incurred by those adhering to a group known as, among other things, the Community of Our Lady of the Nations, or the Army of Mary. Ordinations associated within the group attempted by Father Jean-Pierre Mastropietro were also declared in valid, and other ecclesiastical consequences (such as irregularity for the exercise of orders per 1983 CIC 1044) were declared. See also CCCB Doctrinal Note of 29 June 2001. Update: On 26 September 2007, six religious women in the Diocese of Little Rock AK who formally associated with the Army of Mary were declared excommunicated for remaining in the group. Arkansas Catholic. The case is unusual in that the penalties were declared by the diocesan administrator, the see of Little Rock having been vacant for over one year by this time. Also, a few other women religious, though members of the group, were not censured on account of their old age and doubtful mental freedom in regard to the decision.
On 9 May 2007, speaking extemporaneously to reporters, Pope Benedict XVI made remarks that seemed to support the excommunication of legislators in Mexico City who had recently approved a measure legalizing abortion in certain circumstances. The same remarks, however, also seemed to equate "excommunication" (a canonical penalty in response to crime, per 1983 CIC 1331) with "withholding of Communion" (a canonical disciplinary norm in response to grave sin, per 1983 CIC 915). The pope's remarks were at first confirmed by a Vatican spokesman. Great confusion spread rapidly, which I addressed in my blog, and after a few hours an interim "clarification" that backed-off from the earlier assertions about excommunication was released. On 10 May, the revised version of the pope's remarks avoided mention of excommunication in specific cases, and focused on the consequences of pro-abortion activity for the reception of Communion. Update: 14 May, the high number of commentators who continue to confuse "excommunication" and "withholding Holy Communion" is distressing; one of the most prominent writers who does not confuse the two is Phil Lawler at Catholic World News.
On (Holy) Thursday,
5 April 2007,
LifeSiteNews.com reported: "A second Mexican bishop has issued an explicit
warning to Mexico City’s legislatures [sic] cautioning them that, should they
vote in favor of proposed legislation that would legalize abortion, they would
be automatically excommunicated upon the death of the first baby under the new
law." See also
LifeNews.com. How this position can be reconciled with the plain terms
of 1983 CIC 18, 1329
§ 2, and
1397 was not set out. Moreover, the passages actually quoted from the first
purported excommunication threat do not in fact threaten excommunication for
On Friday, 2 February 2007, Salzburg auxiliary bishop Andreas Laun announced that one Richard Lugner had excommunicated himself under 1983 CIC 1041, n. 1, for having allowed an abortion clinic to rent space in one of his malls. This is canonically impossible, and Vienna's Cdl. Schoenborn has "distanced" himself from the announcement. See original news report here, and my Canon law blog here. LifesiteNews.
On Wednesday, 14 February 2007, it was reported from India that parents who marry-off underage children are being excommunicated. As reported, the diocesan actions are ambiguous cannot be clearly identified as excommunications. See original news article here.
On 24 September 2006, in Washington DC, Abp. Emmanuel Milingo (emer. Lusaka, Zambia), ordained sine mandato and/or installed to the episcopate four American clerics, George Stallings Jr., (Washington, DC), Peter Paul Brennan (New York), Patrick Trujillo (Newark), and Joseph Gouthro (Las Vegas). Catholic World News, Baltimore Sun. Excommunications latae sententiae under 1983 CIC 1382 against all five men were announced by Vatican Press Office on 26 September 2006. Vatican Information Service, In the Light of the Law, Jimmy Akin.
On 31 August 2006, LifeNews.com corrected an earlier disputed report that Alfonso Cdl. Lopez Trujillo had said that anyone involved in an abortion performed on an 11-year-old girl in Columbia would be excommunicated [per 1983 CIC 1398]. Guardian Unlimited (reporting the excommunication assertion), Catholic News Service (saying the cardinal referred the matter to local ecclesiastical officials), Catholic News Agency.
On 26 August 2006, in Jacksonville FL, Bp. Victor Galeone excommunicated Fr. Rouville Fisher (St. Augustine FL) for affiliating with Rent-a-Priest/CITI and agitating for married clergy. National Catholic Register, In the Light of the Law.
On 15 August 2006, Fr. Eduardo Aguirre was excommunicated, apparently for schism for having distanced himself "from the communion and the norms of his priesthood" by founding the Saint Mary of the New Exodus Community in 2003, by the Abp of Guatemala City, Rodolfo Cdl. Quezada Toruño. Prenselibre.com 22 Oct 2007.
On 4 August 2006, Ersilio Cdl. Tonini called for the excommunication of Madonna (Madonna Louise Ciccone) for "open act of hostility" to the Faith. LifeSite. No canonical action has been taken in response to this call.
On 29 June 2006, Alfonso Cdl. Lopez Trujillo of the Pontifical Council for the Family asserted that excommunication would be applied to scientists who carry out embryonic stem research and to politicians in several European countries who approve the practice [per 1983 CIC 1398]. Italian Prof. Cesare Galli named himself and Dra. Elena Cattaneo as likely targets of such excommunications. Telegraph, In the Light of the Law, Jimmy Akin.
On 30 April and 2 May 2006 respectively, Fr. Liu Xinhong and Ma Yinglin received episcopal ordination sine mandato from up to nine bishops. On 4 May 2006 a statement condemning the ordination was issued by the Vatican Press Office and warned of severe canonical consequences (citing 1983 CIC 1382); the statement stopped short of announcing that excommunications has been incurred, despite widespread media claims that they had. Vatican Press Office, ABC News, BBC, Catholic News Service, Asia News, In the Light of the Law I, In the Light of the Law II, Jimmy Akin I, Jimmy Akin II. On 21 Dec 2006: Hong Kong Cdl. Zen has called for the excommunication of illicitly ordained bishops.
On 12 May 2006, Pedro Cdl. Rubian Saenz, Archbishop of Bogota, Columbia, threatened excommunication on all those who commit abortion [per 1983 CIC 1398] under the terms of a Columbia Supreme Court decision legalizing same, and implying that lawmakers and other who assist in the legalization are also subject to the penalty. Catholic News Agency.
On 9 April 2006, Bp. Nicola De Angelis of Peterborough (Canada) declared Fr. Edward Cachia, already under suspension for activities related to the "ordination" of women, to have incurred automatic excommunication for schism (1983 CIC 1364). Catholic On-Line, 12 April 2006.
Excommunication ferendae sententiae under 1983 CIC 1364 (heresy, schism) and dismissal from the clerical state was judicially imposed by the Tribunal of the Diocese of San Bernardino CA against the Rev. Ned Reidy, csc. Press-Enterprise (trial), Press-Enterprise (verdict), Roman Catholic Blog.
On 16 December, in St. Louis MO, Abp. Raymond Burke declared excommunication latae sententiae under 1983 CIC 1364 § 1 (schism) against Fr. Marek Bozek (Springfield-Cape Girardeau) and the Board of Directors of St. Stanislaus Kostka Parish (St. Louis) who were Joseph Rudawski, John Baras, William Bialczak, Edward Florek, Stanley Novak, and John Robert Zabielski; the archbishop also suppressed the Polish parish. St. Louis Review, In the Light of the Law. On 15 May 2008, recourse against the excommunication was rejected. See http://stlouiscatholic.blogspot.com/2008/05/cdf-rejects-recourse-by-st-stanislaus.html and Catholic World Report.
On or about 13 December 2005, Bishop Ulises Casiano Vargas (Mayaguez, Puerto Rico) imposed ferendae sententiae excommunication of the members of sect led by Edwin Gonzalez Concepcion who had declared himself to be the reincarnation of Pope John Paul II and labeled Pope Benedict XVI as the Antichrist [presumably per 1983 CIC 1364 (schism)]. A canonical warning was also issued to Galdys Miranda for claming to be the Blessed Virgin Mary. WWRN
On 25 July 2005, on the St. Lawrence River near Gananoque Ontario, nine women, namely Michele Birch-Conery (Canadian, "priest"), Victoria Rue (American, "priest"), Jean Marie St. Onge (American, "priest"), Marie David of Massachusetts (American, "priest"), Rebecca McGuyver (American, "deacon"), Dana Reynolds (American, "deacon"), Regina Nicolosi (American, "deacon"), Kathleen Sullivan Vandenberg (American, "deacon"), and Kathleen Strack (American, "deacon"), --some names may be pseudonyms-- accepted "ordination" from three female "bishops", Christine Mayr-Lumetzberger, Gisela Foerster, and Patricia Fresen. EEWC. There has apparently been no statement regarding excommunication in this case.
On or about 22 July 2005, the Abp. Liborius Nashendant, omi, of Namibia, imposed a ferendae sententiae excommunication against Fr. Gert Petrus (Namibia) for drunkenness and practicing witchcraft [no canon cited]. It appears that state authorities ratified the canonical decision and ordered Petrus to vacate ecclesiastical property. WWRN.
Some time in 2003, Fr. Anthony Garduno (San Bernardino) was put on trial before the Tribunal of the Diocese of San Bernardino CA for heresy and/or schism (1983 CIC 1364), found guilty, and removed from the clerical state. Sources are unclear as to whether excommunication was also imposed. News: Press-Enterprise (mention), Hanscom Family Weblog
On 11 November 2002, the Policarpa Salavarrieta wing of the Revolutionary Armed Forces of Colombia (FARC) kidnapped Bishop Jorge Enrique Jimenez Carvajal of Zipaquira, then president of the Latin American bishops' conference CELAM. That afternoon Pedro Cdl. Rubiano Saenz of Bogota, the president of the Colombian bishops' conference, in demanding the bishop's release, announced that "the kidnappers have incurred in a grave crime according the canon law, which implies a break in communion of the Church", which was interpreted to mean that the kidnappers had incurred excommunication, [presumably under 1983 CIC 1364 § 1 (schism), but see 1983 CIC 1370 § 2)].
On 29 June 2002, on the Danube River near Linz Austria, Romulo Antonio Braschi (a schismatic bishop), attempted to ordain seven Catholic women to the priesthood: Christine Mayr-Lumetzberger (Austrian), Adelinde Roitinger (Austrian), Gisela Forster (German), Iris Müller (German), Ida Raming (German), Pia Brunner (German), and Dagmar Braun Celeste (aka Angela White, Austrian/American). National Catholic Reporter. On 10 July 2002, the Congregation for the Doctrine of the Faith issued a warning in accord with 1983 CIC 1347 § 1 that the women faced excommunication after 22 July 2002. Zenit ZE02071004. On 5 August 2002, excommunication ferendae sententiae was declared by the Congregation for the Doctrine of the Faith against all seven women. EWTN Library. On 21 December 2002, following a review as requested by the women, the excommunication was confirmed by the Congregation for the Doctrine of the Faith and specified that the Congregation was acting in accord with 1983 CIC 1319 § 1. The operative provision of the confirmation decree had been approved by John Paul II in forma specifica on 20 December 2002. Zenit ZE03012702.
On or about 15 September 2001, Monsignior Iván López, the Archbishop of Popayán, Columbia, excommunicated Communist terrorists who broke into a parish church in Almaguer, province of Cauca, and dynamited an historical altar, the church, the rectory, and several homes in the town. Because the tabernacle and consecrated Hosts were destroyed, excommunication was presumably declared in accord 1983 CIC 1367. Christian Soldiers, Catholic World News.
In early March 2000, a Bolivian judge, Juan Luis Ledezma, ordered doctors to perform an abortion on a 12-year-old rape victim. Bishop Jesus Juarez Parraga, secretary of the bishop's conference, said he considered the judge already excommunicated (presumably under 1983 CIC 1398), and indicated that the episcopal conference was considering further legal action against the judge. Catholic Word News.
On 30 July 1999, Abp. Isaias Duarte Cancino of Cali, Colombia, imposed a ferendae sententiae excommunication for sacrilege [presumably per 1983 CIC 1367] against guerrillas of the National Liberation Army who had been holding hostages they had kidnapped from a Catholic Mass the previous May 30. Zenit ZE99080106.
On 19 May 1998, in Ireland, Bp. Michael Cox, once excommunicated but since 1992 reconciled, ordained sine mandato Fr. Patrick Buckley to the episcopate. An official at the Congregation for the Doctrine of the Faith, Fr. Antonio Manna, confirmed the latae sententiae excommunications, [presumably under 1983 CIC 1382], on or about 17 July 1998. National Catholic Reporter.
On 2 January 1997, excommunication latae sententiae under 1983 CIC 1364 § 1 (heresy) was formally declared by Congregation for the Doctrine of the Faith against the Rev. Tissa Balasuriya, omi (Sri Lanka), primarily for views expressed in his book Mary and Human Liberation (1990). EWTN Library, National Catholic Reporter. Reconciliation was effected on 15 January 1998. National Catholic Reporter, NCR's "Chronology of Balasuriya's troubles".
On 22 March 1996, in Lincoln NE, interdict latae sententiae, and, upon one month's contumacy, excommunication latae sententiae, with absolution reserved to the bishop, was threatened beginning 15 April 1996 by Bp. Fabian Bruskewitz (Lincoln), against Catholics in and of the Diocese of Lincoln who attain or retain membership in: Planned Parenthood, Society of Saint Pius X (Lefebvre Group), Hemlock Society, Call to Action, Call to Action Nebraska, Saint Michael the Archangel Chapel, Freemasons, Job's Daughters, DeMolay, Eastern Star, Rainbow Girls, and Catholics for a Free Choice. EWTN Library, The Wanderer (interview). It does not appear that any formal declarations of penalties were ever made. On 24 November 2006, in response to several unpublished communications, Cdl. Battista Re of the Congregation for Bishops expressed agreement with Bp. Bruskewitz's "sentence" and "ruling". Catholic World News, Catholic News Service. Brief statement by Dr. James Coriden, 18 Dec 2006. In February 2007, very incomplete news reports indicated that the Signatura rejected recourse against the excommunications, if some were imposed. Fuller stories indicate the Signatura actually said it had "no competence" over the bishop's actions.
On 28 July 1991, in Rio de Janeiro, Brazil, Fr. Licinio Rangel received episcopal ordination sine mandato from three excommunicated Catholic bishops, for which violation of 1983 CIC 1382 Rangel was excommunicated latae sententiae. Following a letter of repentance on 15 August 2001, reconciliation of Rangel and 25 follower-priests was achieved on 25 December 2001. EWTN Library.
On 1 May 1991, Bp. Joseph Ferrario (Honolulu HI) declared excommunication latae sententiae under 1983 CIC 1364 § 1 (schism) against Patricia Morely. On 3 July 1991, Morley took recourse against this decree to the Congregation for the Doctrine of the Faith. On 4 June 1993, Cardinal Ratzinger declared Bp. Ferrario's decree of excommunication null. EWTN Library, SSPX.
In November 1990, Bp. Rene Gracida (Corpus Christi TX) declared Elva Bustamante to have incurred latae sententiae excommunication under 1983 CIC 1398 for her work as director of an abortion clinic. NY Times.
In June 1990, Bp. Rene Gracida (Corpus Christi TX) declared Rachel Vargas to have incurred latae sententiae excommunication under 1983 CIC 1398 for her work as director of an abortion clinic.
On 5 February 1990, in Washington DC, after a long exchange of public statements (see Canon Law Digest 12: 757-792, many of which documents are also available in various fascicles of Origins 1989/1990), the Archdiocese of Washington stated that Fr. George Stallings had publicly announced his formal and complete break with the Roman Catholic Church and "has excommunicated himself", apparently under 1983 CIC 1364 (schism). The archdiocese warned that any Catholic who "knowingly and willingly renounce[d] his or her Catholic faith to become a full and active member of Fr. Stallings' congregation would also incur automatic excommunication." Origins 20 (1990) 612; Canon Law Digest 12: 792-793.
On 30 June 1988, at Econe Switzerland, Abp Marcel Lefebvre c.s.sp. (emer. Tulle, France), principal consecrator, and Bp. Antonio de Castro Mayer (emer. Campos, Brazil), co-consecrator, ordained sine mandato four priests to the episcopate, namely Bernard Fellay (Swiss), Bernard Tissier de Mallerais (French), Richard Williamson (English), and Alfonso de Galarreta (Spanish/Argentinean). Excommunication latae sententiae under 1983 CIC 1382 and 1983 CIC 1364 § 1 was formally declared on 1 July 1998 by the Congregation for Bishops against Abp. Lefebvre and the four priests he ordained. At the same time, excommunication latae sententiae under 1983 CIC 1364 § 1 (schism) formally declared by the Congregation for Bishops against Bp. Antonio de Castro Mayer. Catholic Culture. Pope John Paul II, Apostolic Letter Ecclesia Dei (2 July 1988), confirmed the excommunication of Abp. Lefebvre and the four priests who received episcopal orders. See generally Canon Law Digest 12: 793-808.
The excommunication on the four priests ordained bishops were remitted 21 January 2009. Light of the Law 24 January 2009.
On 15 June 1987, German theologian Uta Ranke-Heinneman was removed from a teaching post at Essen University. I found no evidence, however, that she was at that time or at any other time excommunicated despite her (and others') repeated claims that she was so penalized. In the Light of the Law Blog, 23 January 2008.
On 21 January 1986, it was announced by a priest of the Diocese of Providence RI that in June 1985, Mary Ann Sorrentino of Rhode Island had received, in response to her inquiry, written confirmation from Bp. Louis Gelineau and Abp. Pio Laghi, that she had incurred latae sententiae excommunication under 1983 CIC 1398 for her work as executive director of a Planned Parenthood abortion clinic in Rhode Island. Angelus.
Some good references: