Contra Janet Smith on Marital Foreplay

Some years ago, Christopher West was criticized for approving of marital sodomy, of the use of anal penetration as a form of foreplay, prior to natural marital relations. The approval is found in West’s work, and well as in the book “Holy Sex” by Gregory Popcak. Other theology of the body teachers have parroted this approval.

Persons who have disagreed with West on this topic, at one point in time or another, include: Fr. Gregory Gresko, Alice von Hildebrand, Fr. Thomas G. Morrow, Fr. Brian W. Harrison, Fr. Roger Landry, David Schindler, and Fr. Jose Granados. On the subject, specifically, of marital sodomy, John Kippley disagrees with West, too (even though he approves of other unnatural sexual acts in marriage). Then we have the teachings of several Saints on the subject, including Aquinas and Liguori, who are both rather specific in their condemnation of these unnatural acts.

In response to criticisms of West, moral theologian Janet E. Smith came to his defense, or rather, to the defense of the husband’s use of his wife’s posterior as a form of foreplay.

In 2009, Smith wrote the following paragraph, as part of a larger defense of West here:

“I never like to talk about anal sex (sorry, I don’t know a good euphemism). As one of my friends has observed about my sensitivities regarding sexual matters, ‘You would censor Shakespeare!’ (I would.) But the fact remains that Catholic couples in today’s world have questions about such issues. Many cannot understand why anal sex could possibly be appealing to anyone (include me and, indeed, West in that group), while others seem to find the act attractive. Certainly there isn’t any ‘Church teaching’ about this action at a magisterial level, but few seem to know that there is a tradition of approval of such behavior as foreplay to intercourse (not to be confused with the biblical condemnation of sodomy which replaces intercourse) by orthodox Catholic ethicists. The principle generally invoked is that consensual actions that culminate in intercourse are morally permissible. People are free to challenge the ‘tradition’ on this point, but it should be acknowledged that West is not a maverick concerning this issue. Indeed, his position is perhaps more ‘conservative’ than that of the ‘tradition.’ In his book Good News About Sex and Marriage, West clearly discourages the practice. Perhaps it is time for ethicists to work on the question, but what Schindler failed to mention is that West’s position is precisely (or even stricter than) what priests have been trained to teach married couples for a very long time.”

The act in question is termed “anal sex” by Smith. She can’t think of any other term to use to describe the act. And that is no wonder, since the act is in fact anal sex. However, she claims that this act is different from sodomy due to the lack of climax. But such a claim is contradicted by the teaching of the Church.

In “Create In Me A Clean Heart”, the USCCB teaches that the sin of masturbation is gravely immoral even when climax does not occur (section III.). The definition of masturbation includes the explanation: “often to the point of orgasm”. In other words, masturbation is still masturbation and is still a grave sin, even when climax is absent.

The Holy See, under Pope Pius XII, condemned a type of gravely immoral sexual act, even when used within marriage, called “amplexus reservatus”. [Denz. 3907] This act is the same as natural intercourse between husband and wife, except that climax is absent for both persons. And the act is condemned by the Magisterium as an intrinsically evil sexual sin.

In addition, the CDF teaches that “the moral order of sexuality involves such high values of human life that every direct violation of this order is objectively serious.” [Persona Humana, n. X]. But to say that direct violations of this order of human sexuality only occur when climax is included in the act is contrary to reason. The Church has condemned intrinsically evil sexual sins, even when climax is lacking.

This teaching stands to reason. It has been reported in the medical literature [1] that a certain percentage of rapists fail to reach climax. Does any reasonable person think that the acts of a rapist are not sexual acts, or are not gravely immoral, if climax is lacking? Certainly, not. The absurd claim that a sexual act, absent climax, is not a sexual act or is somehow justified, is a blatant rationalization for certain desired sexual sins.

So the claim by Smith that what she terms “anal sex” is a moral type of foreplay, as long as climax is lacking, is false. The Magisterium condemns gravely immoral sexual acts, even when climax is absent. What makes sexual sins intrinsically evil is any of the following: the deprivation of the procreative, unitive, and/or marital meanings, or lack of consent (rape), or the breaking of marital vows (adultery), or any combination. Anal sex used as a type of foreplay is inherently non-unitive and non-procreative, and it is not the type of sexual act that God has ordained for marriage, so it is not truly marital, even when the parties are married to one another. The absence of climax does not justify masturbation, nor fornication, nor adultery, nor rape, nor any other sexual sin.

Smith justifies this inherently disordered sexual act by saying: “The principle generally invoked is that consensual actions that culminate in intercourse are morally permissible.” But the Church has taught no such principle. To the contrary, the basic principles of ethics taught by the Church refutes this idea. It is never the case that one act becomes moral by leading up to a second moral act. Bank robbery is not justified by leading up to a donation to charity. Direct abortion is not justified by leading to the saving of the mother’s life. Certain disordered sexual acts are immoral in and of themselves, because of the deprivation of the marital, unitive, and/or procreative meanings. And a good intended end — to prepare for natural marital relations — does not justify the deliberate choice of an intrinsically evil act. So it is never the case that an act becomes moral by being a means to a good end. Both the means and the end must be good.

When an act is used for the purpose (the intended end) of preparing for natural marital relations, that is, for the purpose of foreplay, the act must still be good in and of itself. Some acts of foreplay are moral, and other acts of foreplay are immoral. If we know that an act has the intended end of foreplay, we do not have enough information to justify that act. It might still be immoral. And every intrinsically evil sexual act is inherently wrong, and cannot be justified by any purpose.

Smith claims the Church has no teaching on this subject: “Certainly there isn’t any ‘Church teaching’ about this action at a magisterial level….” That claim is false. The full explanation of Church teaching on marital sexual ethics is found in my book: The Catholic Marriage Bed. But a good summary is also found in this article: Church Teaching on Marital Sexual Ethics. So there are magisterial teachings on unnatural sexual acts in marriage. Smith is either ignorant of these teachings, having not bothered to study the topic before telling the whole world what is and is not Church teaching, or she is deliberately refusing to address the teachings of the Church that are contrary to her own preferred opinion.

Pope Pius XII condemned the idea that all the sexual acts of one session in the marital bedroom are to be treated as a single moral entity, such that the acts of foreplay (acts done “in the preparation”) would be justified by their association with one “normal performance of the act itself” [Address to Midwives 68]. Pope Pius XII also condemned the all-too-common claim today that the wife may climax by means of any unnatural sexual act, outside of natural marital relations [Address to the Second World Congress on Fertility and Sterility, n. 22 and 25]. The use of anal sex by a married couple is condemned in Denz. 3634. Any type of masturbation is condemned by the Church as well. Masturbation does not become moral when done about the same time as natural marital relations. No intrinsically evil act becomes moral by being done about the same time as another act, one that is moral. And the Church has many other teachings on sexual ethics which can be applied to the choices the married couple makes in the bedroom. So it is false to say that “there isn’t any ‘Church teaching’ on this subject.

Smith then calls her approval of marital sodomy a tradition: “few seem to know that there is a tradition of approval of such behavior as foreplay to intercourse (not to be confused with the biblical condemnation of sodomy which replaces intercourse) by orthodox Catholic ethicists.”

My study of this subject found that the use of unnatural sexual acts in marriage is condemned by Saints Jerome, Augustine, Aquinas, Alphonsus Liguori, and Saint Albert the great. Pope Saint John Paul II taught, in his private theology (Theology of the body lectures and in Love and Responsiblity), that each and every marital sexual act must be procreative. The Magisterium also teaches that each single sexual act in a marriage must be unitive and procreative (Humanae Vitae and other documents). And the priests and theologians listed at the start of this article also condemn marital sodomy. That is not a tradition of approval by orthodox Catholic ethicists. It is a tradition of condemnation.

The alleged tradition that Smith cites is nothing other than the usual situation in Catholic theology, there are always some priests and theologians who dissent from Church teaching, who err gravely in one way or another, who disagree with the orthodox common opinion. And in fact, the Holy See, condemning the use of sodomy in marriage, also noted that such an act, “in the judgment of all the learned teachers, is gravely evil….” [Denz. 3634]. So the Church says that the traditional view, in the orthodox judgment of Catholic teachers, rejects this act as “gravely evil”. But Smith blithely approves of this unnatural sexual act, on the basis of a false claim of approval by tradition.

The use of sodomy for purposes of foreplay within marriage does not change the moral nature of that act. It is one of the “acts of grave depravity” condemned by the Catechism of the Catholic Church [n. 2357]. The intended end of an act (“the purpose pursued in the action”) can never justify an act that is intrinsically evil.

Catechism of the Catholic Church: “A good intention (for example, that of helping one’s neighbor) does not make behavior that is intrinsically disordered, such as lying and calumny, good or just. The end does not justify the means.” [CCC 1753; cf. 1756].

In a second article, in 2010, Janet E. Smith again defends the use of anal sex for foreplay in marriage: The Need to Read Carefully. This time, she offers a 5 paragraph defense of marital sodomy. The overall article, though, argues against the position of Alice von Hildebrand in her criticism of Christopher West.

Smith: “Von Hildebrand, rejecting the view that such an act [“anal penetration as a part of foreplay”] could ever be moral, comes perilously close to accusing West of approving sodomy (which, according the definition of traditional Catholic moralists, involves the completion of the sexual act in the anus) whereas he undeniably he rejects such an act.”

Dangerously close? No, von Hildebrand, along with other critics, does accuse West of approving sodomy. The absence of climax does not make sodomy into a moral act, or into a non-sexual act. The teaching of the Church clearly condemns sexual sins, even when climax is lacking, both outside marriage and within marriage (see above). Rape is still rape without climax. Fornication is still fornication, and sodomy is still sodomy.

Smith herself explains the teaching of St. Alphonsus Liguori, which condemns anal penetration, absent climax, for the purpose of foreplay.

St. Alphonsus: “because coitus itself of this kind (even if without insemination) is true sodomy, although not consummated, just as copulation in the natural vessel of another woman is true fornication, even if insemination does not take place.”

The Church’s greatest moral theologian taught that sodomy is still sodomy when climax is lacking. Smith knows this. But she rejects that teaching out of hand.

She mentions that West’s works have the imprimatur. Yes, well the work of St. Alphonsus Liguori and Saint Thomas have the imprimatur, and also a higher form of approval: appointment as Doctor of the Church and as a Saint. All the Saints who have weighed in on this issued have rejected unnatural sexual acts in marriage as always gravely immoral. But, unfortunately, it is not hard to find Bishops today who support almost any error under the sun. So the support that West has from some Bishops is not telling.

Again, Smith claims: “The fact is the Church does not have a formal teaching about the morality of such an action.” That assertion is false, as I explained above. The Magisterium has condemned various unnatural sexual acts in marriage, acts approved by West and Popcak, not only marital sodomy, but various other unnatural sexual acts as well. It is very easy to claim that the Church has no teaching. But where is the proof? Janet Smith has not written any book, chapter of a book, or article of moral theology presenting her theological argument in favor of unnatural sexual acts in marriage. She has written the two articles discussed in this post, but those articles do not examine the teachings of the Church; the articles are largely rhetorical. I have presented proof that the Church does condemn unnatural sexual acts in marriage, and that proof stands unrefuted.

And now for a really crazy claim by Smith: “West simply provided the answer about Church teaching about such an action that has often been given in moral theology classes in seminaries and graduate programs (I don’t know that it is ever addressed at the undergraduate level).”

I’ve heard this idea before, that students who take classes for masters and doctorate candidates learn things that are not presented in undergraduate classes. Secret things. No one knows except these students, who listen to the whisperings of their professors. But of course this is absurd and false.

When I studied theology at Boston College, for my undergraduate degree in philosophy and theology (a double major), there were relatively few masters and doctorate candidates in theology. So the theology department had an interesting rule. Any undergraduate students who were degree candidates in theology could take the graduate level courses alongside the masters and doctorate candidates. So, then, is a certain secret knowledge, laughably pertaining to anal sex, only revealed in graduate level courses? Rolling on the floor laughing. I took more than a few graduate level courses in theology. There is no difference to the content of the teaching. There is no secret knowledge given only to the graduate level students. There are no ideas found only in graduate level courses.

Then, to make Smith’s comment even more absurd, she herself does not have an undergraduate or graduate degree in theology. Her degrees are in Classics (B.A.), Classical Languages (M.A.), and Classical Languages (Ph.D.) She teaches theology to seminarians, but she holds no degrees in philosophy or theology.

Moreover, we all know that Catholic theologians do not only pass on their knowledge through classes. They also publish books and articles. So how would this knowledge be restricted to seminaries and graduate programs? Are the professors forbidden from publishing this secret knowledge? Absolutely ridiculous. And then, on top of all that, Smith is discussing the topic, in an article for a popular Catholic website, not an esoteric theology journal, and West is discussing these things in popular books aimed at the laity in general. What would be the sense to passing on this knowledge in those classes, when the act in question pertains to the marital bedroom? The idea that this tradition of approval for anal sex is found only in seminary and graduate classes is false and deserving of ridicule.

As a matter of fact, the Magisterium has definitively taught the following.

USCCB Catechism: “Each and every sexual act in a marriage needs to be open to the possibility of conceiving a child.” [USCCB Catechism, p. 409]

Pastoral Letter of the U.S. Bishops: “A marriage is only as open to procreation as each act of intercourse is, because the whole meaning of marriage is present and signified in each marital act. Each marital act signifies, embodies, and renews the original and enduring marital covenant between husband and wife.” [Pastoral letter of the U.S. Bishops, “Marriage: Love and Life in the Divine Plan”]

In addition, Humanae Vitae teaches that “each single act”, meaning each sexual act in a marriage, must retain both the unitive and procreative meanings [Humanae Vitae 3, 11-12, 14]. Humanae Vitae specifically rejected the idea that a set of sexual acts could be grouped together so that some non-procreative sexual acts would be justified by association with some procreative sexual acts. This applies to unnatural sexual acts just as to contracepted sexual acts.

But unnatural sexual acts are inherently non-unitive and inherently non-procreative. And the lack of climax does not make these unnatural acts unitive or procreative. Therefore, all unnatural sexual acts are intrinsically evil, even when climax is lacking.

And, as stated above, the Magisterium has specifically condemned anal sex in marriage and has rejected the idea that a sexual act lacking climax is not a sexual act, or cannot be a grave sin. Furthermore, the idea that all the acts of one session in the marital bedroom are justified as “one act” or as a type of foreplay before natural marital relations is also condemned by the Magisterium [Address to Midwives 68].

Moreover, the approval given by West, Popcak, and others extends beyond marital sodomy absent climax. They approve of unnatural sexual acts (oral, manual, and using sex toys) to climax on the wife. And this idea is directly condemned by Pope Pius XII in his Address to the Second World Congress on Fertility and Sterility [n. 22, 25].

Smith speaks as if West only approves of anal foreplay, and only very reluctantly. “West clearly expresses his own disapproval….” Yes, but on the subject of other types of unnatural sexual acts in marriage, including to climax on the wife, West approves unreservedly, despite the explicit condemnation of the same by the Magisterium. So the Church has a teaching, and West is enthusiastic in contradicting that teaching, even if he is reserved in allowing a different grave sexual sin. Smith claims that anal “foreplay” is moral because climax is lacking. But she knows that West and Popcak also approve of unnatural sexual acts in marriage to climax for the wife (climax outside of the natural act). And she fails to mention this fact. It’s just as well. Then she couldn’t say that the Church has no teaching. She couldn’t say that West “expresses his own disapproval”, not for unnatural sexual acts to climax on the wife. No wonder she omits that point.

Smith continues: “I know a professor of moral theology who received his degree from the John Paul II Institute for Marriage and Family who learned there just what West states in his first edition.” Oh, really? Who is that person? Smith cites an anonymous source in support of her position, when there are named sources — Saints, priests, theologians — as well as magisterial sources in contradiction to that position. That makes for an incredibly weak argument, an anonymous professor versus several Saints, named theologians and priests, and cited magisterial documents.

Smith cites a book by Ford and Kelly, Contemporary Moral Theology, published in 1963. But the book does not specifically discuss or approve of anal foreplay. And that book’s authors wrote before Humanae Vitae and before all the teachings of Pope Saint John Paul II. More modern authors have condemned marital sodomy: Fr. Gregory Gresko, Alice von Hildebrand, Fr. Thomas G. Morrow, Fr. Brian W. Harrison, Fr. Roger Landry, David Schindler, and Fr. Jose Granados.

Canon Lawyer, Dr. Ed Peters

Edited to add this section 2018-08-14
Here is a discussion of Janet Smith’s comments on this specific topic in the comments section of a blog post. In several comments, Dr. Peters defends Smith’s position on non-consummated anal foreplay. Elsewhere, he adopts her heretical claim that contraception is not condemned by the Magisterium outside of marriage. It seems they are not only colleagues at the Sacred Heart Seminary, but friends. But when friendship is placed above the love of Christ and faithfulness to the moral law, that is not true friendship.


Dawn Eden Goldstein notes that Prof. Smith made this statement at the Theology of the Body Institute’s first national congress:

Janet E. Smith: “The 1st thing we need to know is God is chasing us down like a lover. Every lover is a pathological stalker. God is a stalker.”

This type of false insight is the rotten fruit of Christopher West’s perverse version of the theology of the body.


Janet E. Smith, a professor of moral theology, who teaches seminary students, has repeatedly publicly approved of the use of unnatural sexual acts in marriage, in particular anal foreplay, as if these acts could be justified as part of a tradition by orthodox theologians. She also claims that the Magisterium has no teaching to the contrary. But after examining the teaching of the Saints, the Church, Sacred Scripture, and present-day orthodox priests and theologians, I can reach no other conclusion that that all unnatural sexual acts are intrinsically evil and gravely immoral, even in marriage. And the assertions to the contrary by Smith are false and unsupportable.

Which is worse? A married couple unfortunately commit some sexual sins in the marital bedroom. Maybe they will repent and confess. But someone who publicly approves and promotes the alleged morality of grave sexual sins does much more harm. How many Catholic couples have been influenced by West, Popcak, and Smith to commit unnatural sexual acts in their marriage? The harm done to souls and to the Sacrament of holy Matrimony is inestimable. Teachers will have the stricter judgment (James 3:1). Rightly so.

Janet E. Smith is doing much harm to souls by promoting grave sexual immorality to her seminarian students, to her readers, and to her listeners when she gives talks. What will happen when those seminarians become priests, and they have to advise married persons in the confessional? If they accept her errors, they will end up using the Sacrament of Forgiveness to promote and approve of grave sexual sins. And Smith, for her part, can’t be bothered to read the magisterial teachings on this subject and present a comprehensive theological argument.

Eventually, the Church is going to sharply rebuke Christopher West, Gregory Popcak, and Janet Smith. But until then, they will continue to harm souls while falsely claiming to present Church doctrine and sound theology.

{5:20} Woe to you who call evil good, and good evil; who substitute darkness for light, and light for darkness; who exchange bitter for sweet, and sweet for bitter!
{5:21} Woe to you who are wise in your own eyes, and prudent in your own sight!

More Reading: The Catholic Marriage Bed

Ronald L. Conte Jr.
Roman Catholic theologian