They shouldn’t be.
We can pray for the repose of the soul of anyone, and a requiem Mass is simply the prayer of the church for the repose of someone’s soul.
To do so is an act of mercy and faith.
If the person is a family member of Catholics it is even more appropriate if they desire a requiem Mass for that person.
The only prohibition on a requiem Mass is found in Canon Law:
Can. 1184 §1 Church funeral rites are to be denied to the following, unless they gave some signs of repentancebefore death:
1° notorious apostates, heretics and schismatics;
2° those who for anti-christian motives chose that their bodies be cremated;
3° other manifest sinners to whom a Church funeral could not be granted without public scandal to the faithful.
2 If any doubt occurs, the local Ordinary is to be consulted and his judgement followed.
Was Tony Palmer a “notorious heretic, apostate and schismatic”? Of course not.
A notorious apostate, heretic and schismatic is someone who publicly shakes his fist in the face of God and his church. Wild eyed atheists, fundamentalist Protestants and those who defy and disobey the church publicly are such.
Tony Palmer, by all accounts, was a sincere, good and zealous brother in Christ–albeit still separated from full communion with the Church. He may have formally been a heretic and schismatic, but notorious? No. On the contrary, he was full of affection, admiration and desire for the Catholic faith.
If he was like I was in the few years before I entered full communion he would have given whole hearted assent to every Catholic belief. Where he was still learning he was still affirming the faith not rejecting it.
If there was any doubt–which this witness at the funeral suggests–the local ordinary was consulted and gave consent. Everything therefore was just as it should be.
Then there is the question of him being “buried as a bishop”. No one seems to know what that means. There is no special funeral rite for a bishop. One or two different prayers perhaps, and was he in the coffin in episcopal miter and cope? Who knows.
There is also the question of whether Tony Palmer is a bishop at all. The history of his denomination–the Communion of Evangelical Episcopal Churches recounts how, after they elected their first bishops they ensured that they were consecrated by bishops from the Old Catholic and Eastern Orthodox line of succession. It is very possible, therefore that Tony Palmer’s episcopal ordination was valid but irregular. This is the case with many bishops and clergy within the Anglican constellation of churches.
I remember when my friend Bishop Graham Leonard–the former Bishop of London told me about his meeting with Cardinal Ratzinger. Bishop Leonard explained how he and many other Anglican Bishops of an Anglo Catholic persuasion had received valid orders through the Old Catholic and Eastern Orthodox successions. He said Ratzinger smiled and said, “I will not say that you are not a bishop.” Graham Leonard then went on to receive conditional ordination as a Catholic priest.
While everyone admits that Tony Palmer was not a Catholic bishop, and he was not a mainstream Anglican bishop, we can at least say that he was a bishop within his own jurisdiction and that his orders were probably valid but irregular.
There is therefore no reason at all to get all worked up over the fact that he was granted a Catholic requiem Mass or that he was “buried as a bishop” whatever that curious phrase means.