My first instinct is to agree with Joan M’s comments above. However, I have also found the following comments in the book
Handbook of Moral Theology, by Dominic M Prummer, published originally in the 1950’s. They may explain the priest’s attitude (paragraph numbers from the book are given):
3. The Recidivist.
714. Definition. In the strict and formal meaning of the term,
a recidivist is one who after repeated confession (on three or four occasions) frequently falls into the same sin with the result that there exists just reasons for doubting the good will of the penitent.
In the wide sense of the term everyone must be considered a recidivist, since man falls again into the same sins after his confession. But it is not of such recidivists that we speak here. What we may consider the characteristic sign of the formal recidivist seems to be that after repeated confession
(on three or four occasions) the penitent commits the same sin in similar circumstances of time and place, so that one may prudently infer the continuance of an evil will in the penitent.
- Absolution. In normal circumstances the recidivist cannot be absolved unless he shows special signs of sincerity such as to destroy the presumption against him of suitable dispositions.
It is possible the priest referred to may be thinking of the situation described above. However the book by Father Michael Woodgate (2008), A Priest’s Guide to Hearing Confessions, published by the Catholic Truth Society of the UK, asks when absolution should be refused. The start of his answer (which covers an entire chapter) reads:
Rarely! This needs to be said first of all. But we have to remmeber the words of Our Lord: “whosoever sins you retain, they are retained”. In order to receive forgiveness, one must have committed and confessed a sin, as noted in an earlier section. The priest in the confessional does have the role of judge and must know when and to whom absolution should be either conferred, refused or defered. Rit Rom. 3 c.xii says: “Moreover the priest must take into consideration when absolution may be given, when and to whom it must be denied or deferred, for fear that he give absolution to those who refuse to lay aside quarrels and emnities, who refuse to make such restitution as is possible, who refuse to abandon a proximate occasion of sin, or to give up their sins in some other way and amend their lives, or such have given public scandal without making public restitution and thus removing the scandal”. A penitent to whom absolution should be denied is one who is clearly impenitent, showing no sign of sorrow, who efuses to set aside what is causing scandal.
So perhaps the priest may have been thinking of some clear situation where there was something missing in the person’s confession, a lack of willingness to try to change, which he felt was indicated by continuing in the same sins.