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DOUGLAS BIENVENU, JL JUDICIAL DISTRICT COURT
JOHN DOE 1, JOHN DOE 2,
JOHN DOE 3, JOHN DOE 4,
JOHN DOE 5, JOHN DOE 6,
JOHN DOE 7, JOHN DOE 8,
JOHN DOE 9, and JOHN DOE 10

vs, DOCKET NO. PARISH OF ST. MARTIN

 

SOCIETY OF THE ROMAN

CATHOLIC CHURCH OF THE

DIOCESE OF LAFAYETTE and

SAINT MARTIN DE TOURS

CATHOLIC CHURCH STATE OF LOUISIANA


ORIGINAL PETITION FOR DAMAGES
THIS IS THE JOINT PETITION of DOUGLAS BIENVENU, JOHN DOE 1,
JOHN DOE 2, JOHN DOE 3, JOHN DOE 4, JOHN DOE 5, JOHN DOE 6, JOHN DOE
7, JOHN DOE 8, JOHN DOE 9, and JOHN DOE 10, individuals suing for acts that
occurred in St. Martin Parish, Louisiana, who seek damages for the following reasons:
I.
Made defendant herein is SOCIETY OF THE ROMAN CATHOLIC CHURCH
OF THE DIOCESE OF LAFAYETTE, INC., a Louisiana religious corporation with its
principal place of business in Lafayette, Louisiana.
2.
Made defendant herein is SAINT MARTIN DE TOURS CATHOLIC CHURCH,

with its place of domicile in Parish of Saint Martin, Louisiana.

Saint Martin de Tours Church is one of the oldest Catholic churches in America
and the third oldest in the state of Louisiana. It was founded in 1765 by a group of
Acadian exiles who were driven from Canada by the English. The current church

structure was built in 1836. Two other buildings on the church square include the two

 

 

 

 

story parish hall and the rectory, where much of the abuse inflicted by Father Morvant
occurred. Over the years, the church has become a place where countless faithful have
encountered god. Unfortunately, it has also been the scene of the tragedy that occurred
to the young minors in this lawsuit who had the power of their faith perverted in a
disgusting manner.

4.

Beginning in 1971 and continuing until at least 1979, Plaintiffs were all victims of
sexual molestation at the hands of Father Kenneth Morvant. The abuse that Morvant
inflicted on all of the minors was consistent in its use of both alcohol and the power of
God to prey on minors who attended and were altar boys at the St. Martin de Tours
Catholic Church.

5.

The abuse in?icted by Morvant caused emotional damage and pain, which
continues to this date, and is tortious conduct that is ongoing in nature. All of the
Plaintiffs developed dissociative amnesia following the abuse and repressed the
incidents. Following recovery of the memories of sexual abuse in?icted by their priest,
Plaintiffs timely commenced suit against the Defendants in the Superior Court of the
District of Columbia. That lawsuit, Case No. 17-000927, john Doe 1, et at. v. United States
Conference OfCetholic Bishops, was served on the Defendants herein, who appeared in, and
ultimately had the claims dismissed for lack of personal jurisdiction. Pursuant to Article
3462 of the Louisiana Civil Code, prescription was interrupted for the two defendants

sued herein as a result of the filing of Case No. 18-000927.

From 1971 to 1973, Douglas Bienvenu was molested repeatedly by Father Kenneth
Morvant. During the time when this Plaintiff was only 8 to 9.5 years old, Morvant plied

him with alcohol and sexually molested him on at least 15 separate occasions. The acts

 

in?icted on Plaintiff by Father Morvant included the following: removing Plaintiff?s
clothing while asleep or drunk, physical touching of Plaintiff, and masturbation by
Morvant. Plaintiff was so traumatized by the abuse that occurred that he developed
dissociative amnesia to repress the incidents. Father Morvant?s acts in?icted emotional
damage and pain that is ongoing in nature and impacts Plaintiff every single day.

7.

John Doe 1 was 12 years old when he was molested by Morvant in 1976. On at
least three occasions this Plaintiff was invited to spend the night at the rectory with Father
Morvant. He was plied with alcohol on each of these nights before passing out. The
acts in?icted on Plaintiff by Father Morvant included the following: removing Plaintiff?s
clothing while asleep or drunk, physical touching of Plaintiff, and masturbation by
Morvant. Plaintiff was so traumatized by the abuse that occurred that he deveIOped
dissociative amnesia to repress the incidents. Father Morvant?s acts in?icted emotional
damage and pain that is ongoing in nature and impacts Plaintiff every single day.

8.

John Doe 2 was sexually molested by Morvant while attending sleepovers at the
rectory and church during the years 1972-1973. The acts in?icted on Plaintiff by Father
Morvant included the following: removing Plaintiff?s clothing while asleep or drunk,
physical touching of Plaintiff, oral sex performed by Morvant on the Plaintiff, and
masturbation by Morvant. Plaintiff was so traumatized by the abuse that occurred that
he developed dissociative amnesia to repress the incidents. Father Morvant?s acts
inflicted emotional damage and pain that is ongoing in nature and impacts Plaintiff every

single day.

John Doe 3 was molested by Morvant over a four year period between his 8th

grade year and Junior year of high school. The first time Father Morvant met John Doe

3

 

3, Morvant told him: ?God put me here to serve people; God put you here to serve me.?
The acts in?icted on Plaintiff by Father Morvant included the following: removing
Plaintiff?s clothing while asleep or drunk, physical touching of Plaintiff, oral sex
performed by Morvant on the Plaintiff, masturbation by Morvant, placing Plaintiff?s
hand on Morvant?s genitals, and sodomization of the Plaintiff. Plaintiff was so
traumatized by the abuse that occurred that he developed dissociative amnesia to repress
the incidents. Father Morvant?s acts in?icted emotional damage and pain that is
ongoing in nature and impacts Plaintiff every single day.
10.

John Doe 4 sang in choir at St. Martin de Tours Catholic Church at age 14. John
Doe 4 endured molestation in or about 1978-1979. Morvant used to try and corner him
after choir practice to perform further physical assaults. The acts in?icted on Plaintiff by
Father Morvant included the following: removing Plaintiff?s clothing, physical touching
of Plaintiff, oral sex performed by Morvant on the Plaintiff, and masturbation by
Morvant. Plaintiff was so traumatized by the abuse that occurred that he developed
dissociative amnesia to repress the incidents. Father Morvant?s acts in?icted emotional
damage and pain that is ongoing in nature and impacts Plaintiff every single day.

11.

The molestation of John Doe 5 occurred one night following a youth dance.
Morvant invited the Plaintiff and his younger brother to spend the night. Morvant
provided alcohol to the youths, and then molested John Doe 5. The acts in?icted on
Plaintiff by Father Morvant included the following: removing Plaintiff?s clothing while
asleep or drunk, physical touching of Plaintiff, masturbation by Morvant. Plaintiff was
so traumatized by the abuse that occurred that he developed dissociative amnesia to
repress the incidents. Father Morvant?s acts inflicted emotional damage and pain that

is ongoing in nature and impacts Plaintiff every single day.

4

 

12.

In 1977, after his con?rmation ceremony, John Doe 6 was provided alcohol by
Morvant. Once Plaintiff was inebriated, Morvant climbed into bed and assaulted him.
A few months later, following a street fair, Morvant abused him for a second time. The
acts inflicted on Plaintiff by Father Morvant included the following: removing Plaintiff?s
clothing while asleep or drunk, physical touching of Plaintiff, and masturbation by
Morvant. Plaintiff was so traumatized by the abuse that occurred that he developed
dissociative amnesia to repress the incidents. Father Morvant?s acts in?icted emotional
damage and pain that is ongoing in nature and impacts Plaintiff every single day.

13.

John Doe 7 was 14 when Father Morvant provided him with tickets to purchase
beer at the church bazaar. Later that night he was molested by Morvant at the rectory.
The acts inflicted on Plaintiff by Father Morvant included the following: removing
Plaintiff?s clothing while asleep or drunk, physical touching of Plaintiff, and
masturbation by Morvant. Plaintiff was so traumatized by the abuse that occurred that
he developed dissociative amnesia to repress the incidents. Father Morvant?s acts
in?icted emotional damage and pain that is ongoing in nature and impacts Plaintiff every
single day.

14.

John Doe 8 was molested on multiple occasions by Father Morvant when he stayed
at the rectory. Over a two-year period, John Doe 8 was molested approximately two
times per month by Morvant. Like many of the others, Morvant provided him with
alcohol prior to the molestation. The acts in?icted on Plaintiff by Father Morvant
included the following: removing Plaintiff?s clothing while asleep or drunk, physical
touching of Plaintiff, oral sex performed by Morvant on the Plaintiff, masturbation by

Morvant, placing Plaintiff?s hand on Morvant?s genitals, and sodomization of the

5

 

Plaintiff. Plaintiff was so traumatized by the abuse that occurred that he developed
dissociative amnesia to repress the incidents. Father Morvant?s acts in?icted emotional
damage and pain that is ongoing in nature and impacts Plaintiff every single day.

15.

In 19741 John Doe 9 was abused by Morvant at the church rectory. The acts
in?icted on Plaintiff by Father Morvant included the following: removing Plaintiff?s
clothing while asleep or drunk, physical touching of Plaintiff, and masturbation by
Morvant. Plaintiff was so traumatized by the abuse that occurred that he developed
dissociative amnesia to repress the incidents. Father Morvant?s acts in?icted emotional
damage and pain that is ongoing in nature and impacts Plaintiff every single day.

16.

In 1974 John Doe 10 was abused by Morvant at the church rectory. The acts
inflicted on Plaintiff by Father Morvant included the following: removing Plaintiff?s
clothing while asleep or drunk, physical touching of Plaintiff, oral sex performed by
Morvant on the Plaintiff, and masturbation by Morvant. Plaintiff was so traumatized
by the abuse that occurred that he developed dissociative amnesia to repress the
incidents. Father Morvant's acts inflicted emotional damage and pain that is ongoing
in nature and impacts Plaintiff every single day.

17.

Beginning in 1971, the Diocese of Lafayette and St. Martin de Tours Church
exposed Plaintiffs to sexual abuse inflicted by their parish priest, Kenneth Morvant. The
Defendants had a duty to hire, supervise and retain competent, fit, and otherwise
competent priests for St. Martin de Tours Catholic Church and to make sure that children
who attended the church were safe and not exposed to sexual abuse and molestation; and
fully investigate all priests to ensure they were not committing sexual abuse on

minors.

 

18.

These Defendants breached their duties, by, among other things, the following acts
of omissions: hiring Father Morvant to work in a position where he was interacting
with individuals, including minors; failing to supervise Father Morvant so that he
would not pose an unreasonable risk of harm to the parishioners; failing to investigate
Father Morvant to ensure he was not committing sexual abuse on minor parishioners; 
providing Father Morvant with unfettered access to children; and failing to take
prompt remedial action by notifying parishioners that their children had been exposed
to a known or suspected pedophile so that, among other things, the victims of Father
Morvant could receive mental health treatment to prevent any further harm to
themselves.

19.

As a direct and proximate result of the Defendants? wrongful acts or omissions,

Plaintiffs have suffered damages which are ongoing in nature.
20.

At all times relevant to this action, the Defendants had a duty to provide
reasonably safe premises for its parishioners. At all times relevant to this action, the
Defendants knew or should have known that Father Morvant?s conduct would subject
minors to an unreasonable risk of harm on their property. The Defendants breached
their duty by, among other things, the following acts or omissions: failing to warn the
minor Plaintiffs, who were entrusted to the care and attention of the Defendants and
Father Morvant, on premises owned and operated by the Defendants, that they would be
subject to an unreasonable risk of harm on their premises; failing to inform
parishioners, specifically the Plaintiffs, that they had been exposed to a known or

suspected pedophile; failing to take prompt remedial action, including notification to

 

 

?Lidia-"f 

parishioners so that victims of Father Morvant could receive mental health treatment to
prevent any further and/or ongoing harm to themselves and their families.
21.

The Defendants knew or should have known of Father Morvant?s deviant
behavior toward children and recklessly and/or intentionally allowed Father Morvant to
remain a parish priest where he had unfettered access to children. Defendants? conduct
was extreme and outrageous, beyond all possible bounds of decency, and utterly
intolerable in a civilized community. Defendants? conduct directly and proximately
caused Plaintiffs? extreme emotional distress of a nature that no reasonable man could be
expected to endure. This emotional distress is ongoing in nature and continues to this
date. The Plaintiffs suffered and will continue to suffer in the future: severe and
permanent mental distress and emotional injuries as outlined above; financial expenses
for medical and therapeutic care and treatment; long term lost earning capacity; as well
as other damages.

22.

At all times relevant to this action, the Defendants fostered and encouraged the
relationship between priest and parishioner. The Plaintiffs, who were minors when
they were sexually abused by Father Morvant, reposed trust and confidence in the
Defendants, to whom Father Morvant reported. The Defendants, as fiduciaries to the
parishioners and to children entrusted to the care and attention of priests acting on behalf
of them, owed the Plaintiffs a duty of trust and loyalty. The Defendants breached their
fiduciary duty owed to the Plaintiffs and abused its position of trust and confidence. As
a direct and proximate result of the Defendants? breach of fiduciary duty, the Plaintiffs

have been damaged.

 

 

23.

The Defendants? acts and/or omissions rose to the level of gross negligence and
warrant the imposition of exemplary damages. The Defendants consciously ignored
their legal, moral and religious duty to protect the minor children who were serving as
altar boys at the St. Martin de Tours Catholic Church which proximately caused Plaintiffs
damages. While reports of sexual abuse of minors both in the Diocese of Lafayette and
throughout the United States were rampant, Defendants in this lawsuit willfully ignored
what was occurring. These Defendants exhibited conscious indifference to the rights of
the Plaintiffs, which proximately caused their injuries. Furthermore, these defendants
deliberately concealed the proliferation of sexual abuse of minors that was occurring in
the Diocese of Lafayette in order to protect their own interests.

24.

Defendants proximately caused injury to Plaintiffs, which resulted in the
following damages to Plaintiffs: physical pain in the past and future, mental anguish in
the past and future, disfigurement in the past and future, physical impairment in the past
and future, medical expenses in the past and future, loss of earning capacity in the past

and future, exemplary and punitive damages.

 

 

as.)

WHEREFORE, PLAINTIFFS pray for judgment in their favor and against

SOCIETY OF THE ROMAN CATHOLIC CHURCH OF THE DIOCESE OF

LAFAYETTE, INC. and SAINT MARTIN DE TOURS CATHOLIC CHURCH for all

sums to which they are entitled for general and special damages under the laws of this

state or the United States; pre-judgment and post-judgment interest; costs of suit; and all

other relief to which they may be entitled in law or in equity.

PLEASE SERVE:

Respect 11y submitted,

Randy]. ng (Bar B. 12387)
3220 Am ult eet, No. 110
Metairie ouisiana 70002
Telephone: (504) 450-3389
Email: randy@ungar1aw.net
Local Counsel for Plaintiffs

   

AND

Eric]. Rhine

Texas State Bar 0. 24060485 (pro hm: vice to be
submitted)

erhine@spaglaw.com

SPAGNOLETTI CO.

401 Louisiana Street, 8th Floor

Houston, Texas 77002

Telephone: 713.653.5600

Facsimile: 713.653.5656

SOCIETY OF THE ROMAN CATHOLIC CHURCH OF THE DIOCESE OF LAFAYETTE

Serve: Deacon Jeff Trumps
1408 Carmel Drive
Lafayette, LA 70501,

SAINT MARTIN DE TOURS CATHOLIC CHURCH

Serve: Father Rusty Richard

 

133 S. Main Street
Martinville, LA 70582

10