Journal of Catholic Legal Studies

Gotti, Mob Funerals, and the Catholic Church

By: Patrick J. Gordon

John Gotti’s family was denied permission to hold a funeral Mass for the convicted killer. The decision to deny Gotti this fundamental right provided to all Catholics was handed down by Brooklyn Bishop Thomas Daily. Although this is a rather unusual occurrence, John Gotti is not the first organized crime individual to have been denied a funeral Mass. Although Bishop Daily denied Gotti an Ecclesiastic Mass, he compromised by allowing Gotti’s Catholic burial. 

Despite the compromise, this piece suggests that under the circumstances the Bishop—to borrow a term from appellate review—abused his discretion. While, according to the Code of Canon Law, Bishop Daily has the authority to deny an individual such a rite, denial is reserved for extreme circumstances. Specifically, according to Canon 1184, an individual may be deprived of “ecclesiastical funerals” if said person is a “manifest sinner[]” and a funeral Mass cannot be granted without “public scandal of the faithful.”  Still, deprivation can only occur if the person has not repented prior to death. Indeed, the funeral of John Gotti might have brought about “public scandal,” therefore providing grounds for depriving a Mass; however, it seems highly unlikely that in all his time in prison John Gotti did not repent. Supporting this theory are the concepts of “redemption” and “forgiveness.” These notions are so ingrained in Catholic beliefs as to create the inference that the Church wants individuals to achieve salvation and will do all it can to facilitate such. This is further supported by certain Church practices, which I contend assist in creating a presumption that Gotti did repent, thus rendering Canon 1184 inapplicable.

Finally, in past scenarios where individuals were denied funeral rites the overwhelming trend was that they were individuals who had been murdered as a result of their connections with organized crime and presumably had not been allowed any opportunity to receive Penance. Conversely, John Gotti died after a long battle with cancer, making him well aware of his fate, and giving him two years to contemplate his mistakes and to ask for God’s forgiveness.

Before addressing any of the issues set forth, it is important to be aware that this work neither condones the actions of John Gotti nor offers to hold him up as anything more than what he was—the head of a major New York crime family. He was a despicable individual, with the blood of many on his hands. However, according to the beliefs of the Church, and in line with its unification of law and theology, there should have been a much different outcome than that which was reached in the case of John Gotti.