At various times, there have been cardinals who had only received first tonsure and minor orders but not yet been ordained as deacons or priests. Though clerics, they were inaccurately called "lay cardinals" and were permitted to marry. Teodolfo Mertel was among the last of the lay cardinals. When he died in 1899 he was the last surviving cardinal who was not at least ordained a priest. With the revision of the Code of Canon Law promulgated in 1917 by Pope Benedict XV, only those who are already priests or bishops may be appointed cardinals. Since the time of Pope John XXIII a priest who is appointed a cardinal must be consecrated a bishop, unless he obtains a dispensation.

What was a "lay cardinal" allowed to do that is not considered a normal status of a Cardinal?