Was The Second Plenary Council Of Baltimore Infallibly Approved By The Pope?

Aug 22, 2025

Certain dishonest heretics have misrepresented the facts about and the status of the Second Plenary Council of Baltimore, which took place in 1866. They have claimed that the pope at the time, Pope Pius IX, specifically approved and looked over all the decrees that were issued by that national council. Their claim is not true. Those individuals are not only dishonest, but they are often unfamiliar with the basic distinction between something approved in common form (in forma communi) and something approved in specific form (in forma specifica). Only acts approved in the latter way are protected by infallibility. We cover more on that here: https://vaticancatholic.com/the-holy-office-geocentrism-fr-feeney/ But in the case of the Second Plenary Council of Baltimore, its decrees were not approved in common form or in specific form (but merely revised by a Roman Congregation) according to Sebastian Bach Smith, a professor of canon law writing with an imprimatur in 1887. Further explanation is given below, but here are a few key statements he makes.

Sebastian Bach Smith, Elements of Ecclesiastical Law, Imprimatur 1887, Vol. 1, p. 77: “Q. 174. Is the Second Plenary Council of Baltimore approved in forma specifica? A. 1. It is not…”
Sebastian Bach Smith, Elements of Ecclesiastical Law, Imprimatur 1887, Vol. 1, p. 78: “Note: A careful study of the subject would seem to show that the Second Plenary Council of Baltimore was not confirmed by the Holy See in any form, not even in forma communi, but merely revised and corrected [by a Roman Congregation].”

The fact that a Roman Congregation revises a book or a decree does not guarantee that the revised work is without error or definitive or that it’s an act of the Chair of St. Peter. An obvious example of how Roman Congregations and members of Roman Congregations can be wrong is found in the geocentrism controversy. In the 17th century Roman Congregations (with the approval of popes in forma communi) considered the denial of geocentrism to be heresy. But in the 19th century Roman Congregations changed their position and specifically allowed people to embrace heliocentrism. Regardless of which position one takes on that matter, both positions cannot be correct. One must admit that Roman Congregations were wrong either in the 17th century or in the 19th century. But the Chair of St. Peter and the Magisterium are never wrong. This further demonstrates that Roman Congregations are not identical to the Magisterium.

The fact that the Second Council of Baltimore was not approved in forma specifica – and not even in forma communi, according to Smith – is relevant because the decrees of the Second Council of Baltimore contain a few erroneous expressions on the salvation and baptism issue. That should not be a surprise because, as we’ve pointed out repeatedly, the Vatican II apostasy and the breakdown of the faith did not happen three days before Vatican II. The breakdown of the faith began over a hundred years before Vatican II, with errors on the salvation dogma being taught not by the Chair of Peter or the Magisterium but in fallible acts and by various fallible theologians. Many people were falling into serious errors in the 1800s, and this was especially true on the crucial matter of the necessity of baptism and the Catholic Church for salvation. Those who fail to realize this are naïve and ignorant. Man-worshippers who lack divine faith and have no fidelity to the dogmas and the teaching of the Chair of St. Peter cannot comprehend this simple fact. However, it should be noted that the erroneous passages in the Second Council of Baltimore do not teach the blatant and condemned heresy that souls can be saved without any belief in Jesus Christ.

Further, the acts of the aforementioned council open with a profession of faith, taken from the Council of Trent, which correctly asserts that no one can be saved without the Catholic faith and that the sacraments of the New Law are necessary for salvation, although all the sacraments are not necessary for each individual. That means that at least one sacrament (namely, Baptism) is required to be saved, and that everyone must have the Catholic faith to be saved. Unlike the other decrees of the Second Council of Baltimore, the position that the Sacrament of Baptism and the Catholic faith are required for every person’s salvation (which the council repeated through its profession of faith) is infallible because it was also contained in the dogmatic decrees of the Councils of Trent, Vatican I, and more. Thus, while various heretics mispresent the facts about the Second Council of Baltimore – and they attempt to use its fallible and non-definitive decrees to bolster their false position on salvation – they depart from the definitive and infallible profession of faith that was repeated by the same council. Here’s more of what Sebastian Bach Smith said on the matter of the Second Council of Baltimore.

Sebastian Bach Smith, Elements of Ecclesiastical Law, Imprimatur 1887, Vol. 1, pp. 75-78: “What is meant by the confirmation of councils in forma communi and in forma specifica?… Benedict XIV says: ‘Statutes are said to be confirmed in common form, which are not individually examined or approved by the Roman Pontiff motu proprio [of his own accord], et ex certa scientia [from certain knowledge].’ Confirmation in forma specifica is that ‘which is made with perfect knowledge of the whole affair and all of its circumstances.’ Benedict XIV explains this more explicitly: ‘Confirmation in specific form [in forma specifica] is said to be made when it is preceded by an examination of the case and each individual statute is carefully weighed up, and then, with no added condition, confirmation is pronounced by Apostolic Authority with the clause motu proprio and from certain knowledge.’
Q. How can it be known that a provincial or national council is approved in forma specifica and not merely in forma communi? A. 1. When the tenor or contents of its decrees are inserted in the instrument of confirmation. 2. When, in the absence of the above, these phrases are used: ex certa scientia; proprio motu; ex plenitudine potestatis; non obstante lege aut consuetudine in contrarium, or supplentes omnes juris et facti, defectus. 3.) The recognitio by the Sacred Congregation is not sufficient; the confirmation must be given by letters Apostolic.
In case of doubt whether a council is approved in forma specifica or only in forma communi, canonists commonly hold that it is approved merely in forma communi…
Is the Second Plenary Council of Baltimore approved in forma specifica? A. 1. It is not; for the Decretum of the Propaganda, dated Jan. 24, 1868, Pro Recognitione Concilii (Pl. Balt. II.), has none of the marks above given in confirmation of the forma specifica. This appears from the decree itself, which reads: ‘The Same Sacred Congregation, having applied diligent inquiry, with a few corrections and observations excepted, has judged and most willingly recognized the acts and decrees of the same Second Plenary Council of Baltimore, so that the same may be inviolately observed by all to whom they pertain.’ Moreover, the sole revision and approbation of decrees by a Sacred Congregation is not Papal confirmation, at least in forma specifica. For decrees of councils are sanctioned in forma specifica, not by a ‘Decretum S. Congr. pro recognitione concilii’, but by apostolic letters or briefs. Now, the decrees of Baltimore were confirmed, or rather reviewed, not by apostolic letters, but by a Decretum S. C. de Prop. Fide’ above mentioned, as appears clearly from the Holy Father’s reply to the Fathers of Baltimore, Sept. 2, 1867: ‘What pertains to the Acts of the Council (Second Plenary of Baltimore), it is appropriate that you will receive a response concerning the same Acts, after they have been set before our Sacred Congregation for the Propagation of the Faith.’
From what has been said we infer that it is allowed to appeal to the S. C. de Prop. Fide from the decrees of the Second Plenary Council of Baltimore, and also from the decrees of the Third Plenary Council of Baltimore, held in 1884; for, the confirmatio in forma communi does not remove the defectus juris that may be contained in their enactments…
Note: A careful study of the subject would seem to show that the Second Plenary Council of Baltimore was not confirmed by the Holy See in any form, not even in forma communi, but merely revised and corrected [by a Roman Congregation]. ‘Thus, the decree of the Propaganda (C. Pl. Balt. IL., p. cxxxvi.) has for its heading the words: ‘Decretum pro Recognitione Concilii’; but not ‘Decretum pro approbatione or confirmatione Concilii.’”

These facts are sufficient to refute the serious misrepresentations that have been made on this matter by various individuals.