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In the Roman Catholic Church, a "lay cardinal" was a cardinal who had never been given major orders, i.e. who had never been ordained a deacon, priest, or bishop.

Lay Cardinal Teodolfo Mertel

In the Roman Catholic Church, a "lay cardinal" was a cardinal who had never been given major orders, i.e. who had never been ordained a deacon, priest, or bishop.

Properly speaking these cardinals were not laymen, since they were all given what was called first tonsure, by which at that time one became a cleric and ceased being a layman. In addition they were given minor orders, which were no obstacle to marrying or to living in a marriage previously contracted. The freedom to marry and to live in marriage is doubtless the reason that cardinals who were not in major orders were popularly, though inaccurately, referred to as lay cardinals.