Update: The Archdiocese of Milwaukee Responds to Awake’s Questions (Part 2)

By Sara Larson
Awake Leadership Team

As we explained in our previous blog post, Awake submitted a list of questions to the Archdiocese of Milwaukee in December 2019 and received responses to a shorter list of priority questions in January 2020. 

For six of the nine priority questions, we found the answers clear, if not completely satisfactory; we shared those responses in Part 1 of this post. For the remaining three topics, we do not believe the archdiocesan responses adequately answer our questions, so we are still seeking further information. Jerry Topczewski, the Archbishop’s Chief of Staff, has agreed to meet with us again on April 1, and we hope to come to a better understanding of these issues at that meeting. In the meantime, we are sharing the responses we received, as well as a few comments about the clarifications we seek.

(Update, 3/26/20: Due to the coronavirus pandemic, our April 1 meeting has been postponed. We intend to continue the conversation when the public health crisis has passed.)

Responding to Grooming Behavior

Question from Awake Milwaukee: What are the processes in place to receive and respond to complaints about grooming behavior that has not escalated to the level of abuse?

Answer from the Archdiocese of Milwaukee: 

Diocesan Standards for Ministerial Behavior Protocol on Ethical Standards:

  • The Code of Ethical Standards is given to all clergy and church personnel and is available on the Archdiocesan web site.

  • All church personnel and all volunteers who have regular contact with minors or go on a retreat or field trip (even one time) are required to document that they have read, understand, and agree to abide by the Code of Ethical Standards.

  • A summary of the Code dealing with reporting misconduct has been sent to every archdiocesan parish school and religious education program for distribution to families.

  • The Code will periodically be reviewed by the Diocesan Review Board to determine the need for revision.

  • Education programs on the Code will be included in parish, school, and seminary workshops.

The Archdiocese of Milwaukee relies upon its Code of Ethical Standards for Church Leaders, which is on the archdiocesan website and every Church Minister must read, acknowledge and sign a statement that they have read the Code and understand its applicability to my work and/or volunteer efforts for the Church. I also have read the Mandatory Reporting Responsibilities and understand my responsibilities. Several sections would apply to this question of unethical, but not illegal behavior:

  • Church ministers must notify their supervisors or, if needed, other Church authorities of ethical misconduct by another Church minister.

  • When Church ministers are uncertain whether a particular situation or course of conduct would violate this Code of Ethical Standards, they should consult with peers knowledgeable about ethical issues and this Code, or the Chancery Office, in order to determine the proper response.

  • When Church ministers believe that one of their colleagues may have violated this Code of Ethical Standards, they should make a good faith attempt to resolve the issue, if possible, by bringing it to the attention of the individual. If this fails, the Church minister must take further action by reporting to the supervisor or next higher authority, or by referral to the Chancery Office.

  • In cases where there are clear indicators of unethical, but not illegal actions by a Church minister, notification is to be made to a supervisor, or the proper Church authorities.

In addition, all volunteers who have regular contact or go on a retreat or field trip (even one time) with children and young people, are also trained in recognizing and reporting child sexual abuse and all abuses.

Comment from Awake: We are interested in the handling of grooming behavior and boundary violations because of the evidence that these can be early warning signs of future sexual abuse. (For example, a recent independent review of the Archdiocese of Chicago’s child protection policies highlighted the response to grooming behavior as a key area for improvement in the Church’s efforts to prevent abuse.) We would like more information on the exact process for reporting such concerns in our archdiocese and, most importantly, clarification on how these concerns are received, tracked, reviewed, and addressed with the person exhibiting the behavior to prevent escalation to sexual abuse.

Abuse of Adults

Question: What are the Archdiocese’s policies and procedures for reporting, investigating, and responding to claims of sexual harassment, abuse, or misconduct with adults by clergy or other church employees or volunteers? Are those who are victimized as adults entitled to the same investigative process and pastoral care as those who were abused as children?

Answer: The Archdiocese of Milwaukee relies upon its Code of Ethical Standards for Church Leaders and several sections would apply to this question:

  • Church ministers must be committed to establishing and maintaining a professional work environment, which is free from intimidation and harassment. Harassment can occur as the result of a single severe incident, or a pattern of conduct which results in the creation of a hostile, offensive, or intimidating work environment. Harassment encompasses a broad range of physical or verbal behavior, which can include, but is not limited to, the following:

    • physical or mental abuse;

    • racial insults;

    • derogatory ethnic slurs;

    • sexual advances or unwelcome touching;

    • sexual comments or sexual jokes;

    • requests for sexual favors used as a condition of employment, or affecting any personnel decision such as hiring, promotion, compensation, or termination.

  • Church ministers within [and members of] the archdiocese who, in good faith, report a violation of a law or regulatory requirement or ethical standard or who participate in good faith in any resulting investigation or proceeding shall not suffer harassment, retaliation, or adverse employment [or member] consequence. The archdiocese or parish will take disciplinary action (up to and including termination) against an employee who in its assessment and in violation of this policy has engaged in retaliatory conduct against a good faith reporter.

In addition, the archdiocese is working to establish a reporting mechanism through EthicsPoint, as well as an independent lay board of professionals to oversee investigations and make recommendations about an individual’s (clergy or lay) fitness for ministry for items that do not rise to the level of criminal behavior. The hope is to have this in place by July 1, 2020.

Comment from Awake: Because a perceived power differential can create abusive situations between Church leaders and other adults, we seek further clarification about how these situations are handled in our archdiocese. While the Code of Ethical Standards provides some information about what behavior is prohibited, we would like more information about how the Archdiocese reviews allegations of this type and what actions it takes in response. We would also like to learn more about what ongoing support is offered to those who are victimized as adults.

We are encouraged to hear about continued progress toward a Fitness for Ministry Oversight Board, which was promised in the Catholic Herald in May 2019. We hope this plan will be swiftly implemented and the new board will be established with adequate transparency and independence.

Question: What are the Archdiocesan policies about what behavior by a cleric toward an adult would be considered sexually abusive? Does Archdiocesan policy consider any sexual relationship between a cleric and a parishioner or someone seeking spiritual advice abusive? How are these policies communicated to clerics, church employees, volunteers, and other parishioners?

Answer: The Archdiocese of Milwaukee relies upon its Code of Ethical Standards for Church Leaders and several sections would apply to this question:

  • Church ministers must be committed to establishing and maintaining a professional work environment, which is free from intimidation and harassment. Harassment can occur as the result of a single severe incident, or a pattern of conduct which results in the creation of a hostile, offensive, or intimidating work environment. Harassment encompasses a broad range of physical or verbal behavior, which can include, but is not limited to, the following:

    • physical or mental abuse;

    • racial insults;

    • derogatory ethnic slurs;

    • sexual advances or unwelcome touching;

    • sexual comments or sexual jokes;

    • requests for sexual favors used as a condition of employment, or affecting any personnel decision such as hiring, promotion, compensation, or termination.

  • Sexual Misconduct. Church ministers must be knowledgeable of the laws of the State of Wisconsin regarding sexual assault, sexual abuse, and sexual exploitation, and the reporting requirements of the Archdiocese and of civil law which apply to such misconduct.

  • All allegations and concerns involving the sexual abuse of a minor or vulnerable adult, or sexual exploitation, as defined by Wisconsin laws, must be reported promptly to the appropriate civil authorities.

  • Archdiocesan Sexual Abuse Prevention & Response Office is available, as needed, for assistance and consultation on all issues of sexual misconduct, including the notification of proper civil authorities regardless of whether the alleged behavior is past or present.

Comment from Awake: We remain unclear about the Archdiocese’s approach to handling reports of abuse of adults and what consequences would be enforced for clerics who abuse adults. We are aware that other dioceses have clarified these policies in recent years. For example, the Diocese of Oakland’s website states: “Anyone may potentially be victimized by clergy sexual abuse. This includes not only minors, but also young adults and adults, both male and female. Clergy sexual activity can never be consensual on the part of the victim. The Power Differential in the relationship automatically puts the Priest (or Deacon) in the position of power. Therefore, there can never exist a truly mutual consensual agreement. It is the obligation of the priest (or clergy) to hold the sexual boundaries in all relationships.”

Similarly, new policies in the Diocese of Buffalo specify that “An adult will never be considered to have consented when the inappropriate activity arises in the course of pastoral or counseling activities… Meaningful consent to sexual activity requires equality that makes real choice possible. Meaningful consent assumes the absence of any constraint, subtle coercion, or manipulation. The imbalance of power/resources in the ministerial relationship precludes this equality, even when the two persons see themselves as consenting adults. If they are not peers, then there is no meaningful consent.” We are interested to learn if the Archdiocese of Milwaukee has a policy stating that all sexual contact that takes place in the context of confession, spiritual direction, pastoral counseling, or a pastor-parishioner relationship is considered non-consensual and therefore abusive.

Milwaukee Catholics, We Want to Hear from You

As we continue to pursue responses to our complete list of questions, we would appreciate your feedback about which topics are most important to you. Please take a few minutes to select your top 10 questions on our survey here: Questions for the Archdiocese – What Matters Most To You? You can also contact us at awakemke@gmail.com if you have other questions or comments to share, or if you would like to connect with our Advocacy Working Group.


Sara Larson studied theology at Marquette University, worked in parish ministry for eight years, and is a member of Saints Peter and Paul Parish in Milwaukee. She chairs Awake’s Advocacy Working Group.

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