Wyoming Bishop Cleared of Abuse by the Vatican Dies at 91

The Vatican’s doctrinal dicastery cleared him of several of the charges in 2021 while ruling that five other accusations “could not be proven with moral certitude” one way or another.

St. Mary Cathedral in Cheyenne, Wyoming.
St. Mary Cathedral in Cheyenne, Wyoming. (photo: Credit: Always dreamin, CC0 / Wikimedia Commons)

Bishop Joseph Hart, who led the Diocese of Cheyenne, Wyoming, from 1978 until his 70th birthday in 2001, died Wednesday at age 91. 

Bishop Hart was accused on multiple occasions of sexual abuse of minors, charges that he fervently denied. The Vatican’s doctrinal dicastery cleared him of several of the charges in 2021 while ruling that five other accusations “could not be proven with moral certitude” one way or another. 

The Diocese of Cheyenne — which encompasses the entire state of Wyoming — said in a statement to CNA that Hart’s funeral services and burial will be held at the convenience of the family. The diocesan communications director told CNA on Friday that a formal statement on Bishop Hart from the diocese is pending. 

Bishop Hart was accused of sexually abusing children in the mid-1970s, and numerous accusations were levied against him in 1989, 1992, 2002, and 2004. Bishop Hart was additionally accused of solicitation in confession. In 2020, civil prosecutors declined to press charges against Hart due to insufficient evidence of the claims of abuse.

The Diocese of Cheyenne began in January 2018 its own investigation into Hart’s alleged abuse. The diocese later said that its investigative team “were convinced that we had sufficient evidence to conclude with moral certainty that the six accusations against Bishop Hart are credible” and passed the case to the Vatican for a final decision in the canonical process, which began in 2019. 

According to the diocese, the accusations against Bishop Hart involved 11 males and one female. The CDF found that two of the accusers did not meet the standard for abuse of a minor as the alleged victims were 16 and 17 at a time when the Code of Canon Law considered anyone under the age of 16 to be a minor. That age is now 18. 

Despite clearing him of some of the charges, the Vatican dicastery rebuked Bishop Hart “for his flagrant lack of prudence as a priest and bishop for being alone with minors in his private residence and on various trips, which could have been potential occasions endangering the ‘obligation to observe continence’ and that would ‘give rise to scandal among the faithful.’”

In a 2018 statement following the Vatican’s ruling, the Cheyenne Diocese explained that for the dicastery, Bishop Hart’s guilt was not “proven with moral certitude, which is held to be equivalent to ‘beyond a reasonable doubt,’ the legal standard of proof required to impose a criminal conviction. These findings do not equate to innocence; rather, a high burden of proof has not been met.” 

In addition, even after its ruling, the dicastery declined to lift the restrictions imposed on Hart in 2018 and reminded him that he should not have “any contact with minors, youth, seminarians, and vulnerable adults” nor preside over any public celebration of the liturgy. 

In 2020, when Wyoming prosecutors dropped the case against Bishop Hart, current Cheyenne Bishop Steven Biegler issued a statement saying that, despite the lack of criminal charges, he believed the allegations to be credible and supported the alleged survivors of abuse. One of Hart’s accusers, Ed Gavagan, detailed his alleged abuse in the 2021 Netflix documentary “Procession” and said in the film that Biegler was helpful throughout the investigation process. 

Bishop Hart was a priest of the Diocese of Kansas City-St. Joseph, Missouri, from 1956 to 1976. In 2008, that diocese paid a settlement to 47 victims of clerical sexual abuse, some of whom alleged that they were abused by Bishop Hart. 

The Diocese of Kansas City-St. Joseph did not respond by press time to CNA’s request for comment on Hart’s passing.