California Supreme Court rules on ownership issue between national Episcopal church and local parish that seceded.
Article summary. Applying the “neutral principles of law” approach, the California Supreme Court ruled that the national Episcopal Church owned the property of a local church that voted to disaffiliate from the denomination as a result of the ordination of a gay priest. Although for more than fifty years the deeds to the church property vested title in the local church, the court concluded that the local church, from the beginning of its existence, agreed to be part of the Episcopal Church and to be bound by its governing documents. These documents make clear that church property is held in trust for the general church and may be controlled by the local church only so long as it remains a part of the general church. When a church disaffiliates from the general church, it does not have the right to take the church property with it.
The California Supreme Court ruled unanimously that the national Episcopal Church was the legal owner of the property of a local church …
• Key point. Most courts apply the “neutral principles of law” rule in resolving disputes over the ownership and control of property in “hierarchical” churches. Under this rule, the civil courts apply neutral principles of law, involving no inquiry into church doctrine, in resolving church property disputes. Generally, this means applying neutral legal principles to non-doctrinal language in any one or more of the following documents: (1) deeds to church property; (2) a church’s corporate charter; (3) a state law addressing the resolution of church property disputes; (4) church bylaws; or (5) a parent denomination’s bylaws.
The California Supreme Court ruled unanimously that the national Episcopal Church was the legal owner of the property of a local church that had voted to disaffiliate. This feature article will review the facts of the case, summarize the court’s ruling, and evaluate the significance of the case for other churches.
Facts
The Protestant Episcopal Church in the United States of America (the “Episcopal Church”), organized in 1789, was the product of secession of the Anglican church in the colonies from the Church of England, the latter church itself being the product of secession from the Church of Rome in 1534. The Episcopal Church is governed by a general convention and a presiding bishop. In the United States, the Episcopal Church is divided geographically into dioceses, including the Los Angeles Diocese. Each diocese is governed by a diocesan convention and a bishop. A diocese is itself divided into missions and parishes, which are individual churches where members meet to worship. A parish is governed by a rector and a board of elected lay persons called the vestry. One such parish within the Los Angeles Diocese was St. James Parish.
St. James Parish began as a mission of the Episcopal Church in 1946. In 1947, members of the mission sought permission from the Los Angeles Diocese to organize as a parish. The members’ handwritten application “promised and declared” that the Parish would “forever be under, and conform to and be bound by, the ecclesiastical authority of the Bishop of Los Angeles, and of his successor in office, the Constitution and Canons of the Episcopal Church, and the Constitution and Canons of the Diocese of Los Angeles.”
Articles of Incorporation of St. James Parish, filed with the California Secretary of State in 1949, stated that the corporation was formed
to establish and maintain a Parish which shall form a constituent part of the Diocese of Los Angeles in the Episcopal Church; and so that the Constitution and Canons, Rules, Regulations and Discipline of said Church … and the Constitution and Canons in the Diocese of Los Angeles, for the time being shall, unless they be contrary to the laws of this State, always form a part of the Bylaws and Articles of Incorporation of the corporation hereby formed and shall prevail against and govern anything herein contained that may appear repugnant to such Constitutions, Canons, Rules, Regulations and Discipline.
In 1950, the “Bishop of the Protestant Episcopal Church in Los Angeles” deeded the property on which the church building stands to St. James Parish. The deeds to the property have been in the name of the local church ever since.
Canon II.6 of the canons of the general convention of the Episcopal Church provides:
Section 1. No Church or Chapel shall be consecrated until the Bishop shall have been sufficiently satisfied that the building and the ground on which it is erected are secured for ownership and use by a Parish, Mission, Congregation, or Institution affiliated with this Church and subject to its Constitution and Canons.
Section 2. It shall not be lawful for any Vestry, Trustees, or other body authorized by laws of any State or Territory to hold property for any Diocese, Parish or Congregation, to encumber or alienate any dedicated and consecrated Church or Chapel, or any Church or Chapel which has been used solely for Divine Service, belonging to the Parish or Congregation which they represent, without the previous consent of the Bishop, acting with the advice and consent of the Standing Committee of the Diocese ….
Section 4. Any dedicated and consecrated Church or Chapel shall be subject to the trust declared with respect to real and personal property held by any Parish, Mission, or Congregation as set forth in Canon I.7.4.
In 1979, the Episcopal Church added section 4 to Canon I.7 (Canon I.7.4, sometimes referred to as the “Dennis Canon”), which states:
All real and personal property held by or for the benefit of any Parish, Mission or Congregation is held in trust for this Church and the Diocese thereof in which such Parish, Mission or Congregation is located. The existence of this trust, however, shall in no way limit the power and authority of the Parish, Mission or Congregation otherwise existing over such property so long as the particular Parish, Mission or Congregation remains a part of, and subject to, this Church and its Constitution and Canons.
Recently, as a result of a doctrinal dispute, St. James Parish disaffiliated itself from the Episcopal Church. It appears that the dispute leading to the decision to disaffiliate arose after the national church ordained an openly gay man as a bishop in New Hampshire in 2003. Some members of the Episcopal Church, including members of St. James Parish, disagreed with this ordination. In July 2004, the board of St. James Parish voted to end its affiliation with the Episcopal Church and to affiliate with the Anglican Church of Uganda. A majority of the congregation voted to support the decision. After the disaffiliation, a further dispute arose as to who owned the church building that St. James Parish used for worship and the property on which the building stands-the local church that left the Episcopal Church or the higher church authorities.
To resolve this dispute, the Los Angeles Diocese and various individuals, including a dissenter from the decision by St. James Parish to disaffiliate, sued various individuals connected with St. James Parish (defendants). Later, the national Episcopal Church successfully sought to intervene on the side of the Los Angeles Diocese and filed its own complaint in intervention against the defendants. In essence, both sides in this litigation, i.e., defendants on one side, and the Los Angeles Diocese and Episcopal Church allied on the other side, claim ownership of the local church building and property on which it stands.
The trial court resolved the dispute over ownership of church property in favor of the local church, and a state appeals court ruled in favor of the Episcopal Church. The California Supreme Court accepted an appeal of the case in order to decide “how the secular courts of this state should resolve disputes over church property.”
“Although the deeds to the property have long been in the name of the local church, that church agreed from the beginning of its existence to be part of the greater church and to be bound by its governing documents. These governing documents make clear that church property is held in trust for the general church and may be controlled by the local church only so long as that local church remains a part of the general church. When it disaffiliated from the general church, the local church did not have the right to take the church property with it.”
The California Supreme Court’s ruling
Introduction
The California Supreme Court began its ruling by observing:
In this case, a local church has disaffiliated itself from a larger, general church with which it had been affiliated. Both the local church and the general church claim ownership of the local church building and the property on which the building stands. The parties have asked the courts of this state to resolve this dispute. When secular courts are asked to resolve an internal church dispute over property ownership, obvious dangers exist that the courts will become impermissibly entangled with religion. Nevertheless, when called on to do so, secular courts must resolve such disputes. We granted review primarily to decide how the secular courts of this state should resolve disputes over church property.
State courts must not decide questions of religious doctrine; those are for the church to resolve. Accordingly, if resolution of the property dispute involves a doctrinal dispute, the court must defer to the position of the highest ecclesiastical authority that has decided the doctrinal point. But to the extent the court can resolve the property dispute without reference to church doctrine, it should use what the United States Supreme Court has called the “neutral principles of law” approach. The court should consider sources such as the deeds to the property in dispute, the local church’s articles of incorporation, the general church’s constitution, canons, and rules, and relevant statutes, including statutes specifically concerning religious property, such as Corporations Code section 9142.
When secular courts are asked to resolve an internal church dispute over property ownership, obvious dangers exist that the courts will become impermissibly entangled with religion.
Applying the neutral principles of law approach, we conclude that the general church, not the local church, owns the property in question. Although the deeds to the property have long been in the name of the local church, that church agreed from the beginning of its existence to be part of the greater church and to be bound by its governing documents. These governing documents make clear that church property is held in trust for the general church and may be controlled by the local church only so long as that local church remains a part of the general church. When it disaffiliated from the general church, the local church did not have the right to take the church property with it.
How California Courts Should Resolve Disputes Over Church Property
The court noted that decisions by the United States Supreme Court provide the following guidelines in the resolution of church property disputes:
- The civil courts may resolve church property disputes, but only if they can do so without “entangling” themselves in disputes over church doctrine.
- How state courts resolve church property disputes is a matter of state law.
- The method a state chooses must not violate the First Amendment to the United States Constitution.
- The First Amendment prohibits civil courts from resolving church property disputes on the basis of religious doctrine and practice.
- The Amendment requires that civil courts defer to the resolution of issues of religious doctrine or polity by the highest court of a hierarchical church organization.
- Subject to the preceding limitations, the First Amendment does not dictate that a state must follow a particular method of resolving church property disputes. Indeed, a state “may adopt any one of various approaches for settling church property disputes so long as it involves no consideration of doctrinal matters, whether the ritual and liturgy of worship or the tenets of faith.” Jones v. Wolf, 443 U.S. 595 (1979).
- The United States Supreme Court has approved two methods for resolving church property disputes. Under the “principle of government” approach (sometimes called the “compulsory deference” approach), “whenever the questions of discipline, or of faith, or ecclesiastical rule, custom, or law have been decided by the highest of these church judicatories to which the matter has been carried, the legal tribunals must accept such decisions as final, and as binding on them, in their application to the case before them.” Watson v. Jones, 80 U.S. (13 Wall.) 679 (1871). The second approach is called the “neutral principles of law” approach. Under this approach, the civil courts “rely upon provisions of state statutory law governing the holding of property by religious corporations, upon language in the deeds conveying the properties in question to the local church corporations, upon the terms of the charters of the corporations, and upon provisions in the constitution of the [national church] pertinent to the ownership and control of church property.” Md. & Va. Churches v. Sharpsburg Church, 396 U.S. 367 (1970).
- The Supreme Court has observed: “Through appropriate reversionary clauses and trust provisions, religious societies can specify what is to happen to church property in the event of a particular contingency, or what religious body will determine the ownership in the event of a schism or doctrinal controversy. In this manner, a religious organization can ensure that a dispute over the ownership of church property will be resolved in accord with the desires of the members.” Jones v. Wolf, 443 U.S. 595 (1979).
- However, the Supreme Court has cautioned: “The neutral-principles method … requires a civil court to examine certain religious documents, such as a church constitution, for language of trust in favor of the general church. In undertaking such an examination, a civil court must take special care to scrutinize the document in purely secular terms, and not to rely on religious precepts in determining whether the document indicates that the parties have intended to create a trust. In addition, there may be cases where the deed, the corporate charter, or the constitution of the general church incorporates religious concepts in the provisions relating to the ownership of property. If in such a case the interpretation of the instruments of ownership would require the civil court to resolve a religious controversy, then the court must defer to the resolution of the doctrinal issue by the authoritative ecclesiastical body.” Jones v. Wolf, 443 U.S. 595 (1979).
- The “departure from doctrine” approach for resolving church property disputes on the basis of which party has departed from church doctrine is impermissible since it requires a judicial determination of doctrine.
The California Supreme Court concluded, based on this precedent, that civil courts called upon to resolve church property disputes should proceed as follows:
State courts must not decide questions of religious doctrine; those are for the church to resolve. Accordingly, if resolution of a property dispute involves a point of doctrine, the court must defer to the position of the highest ecclesiastical authority that has decided the point. But to the extent the court can resolve a property dispute without reference to church doctrine, it should apply neutral principles of law. The court should consider sources such as the deeds to the property in dispute, the local church’s articles of incorporation, the general church’s constitution, canons, and rules, and relevant statutes, including statutes specifically concerning religious property, such as Corporations Code section 9142.
Resolving the Dispute of This Case
The court acknowledged that St. James Parish holds title to the property in question, and noted that “this is the fact that defendants rely on most heavily in claiming ownership.” On the other hand, from the beginning of its existence, St. James Parish
promised to be bound by the constitution and canons of the Episcopal Church. Such commitment is found in the original application to the higher church authorities to organize as a parish and in the articles of incorporation. Canon I.7.4, adopted in 1979, provides that property held by a local parish “is held in trust” for the general church and the diocese in which the local church is located. The same canon states that the trust does not limit the authority of the parish over the property “so long as the particular Parish … remains a part of, and subject to, this Church and its Constitution and Canons.” Other canons adopted long before St. James Parish existed also contained substantial restrictions on the local use of church property.
The question to be decided, then, was “which prevails-the fact that St. James Parish holds title to the property, or the facts that it is bound by the constitution and canons of the Episcopal Church and the canons impress a trust in favor of the general church?” The court again quoted from the United States Supreme Court’s decision in Jones v. Wolf:
Under the neutral-principles approach, the outcome of a church property dispute is not foreordained. At any time before the dispute erupts, the parties can ensure, if they so desire, that the faction loyal to the hierarchical church will retain the church property. They can modify the deeds or the corporate charter to include a right of reversion or trust in favor of the general church. Alternatively, the constitution of the general church can be made to recite an express trust in favor of the denominational church. The burden involved in taking such steps will be minimal. And the civil courts will be bound to give effect to the result indicated by the parties, provided it is embodied in some legally cognizable form. Jones v. Wolf, 443 U.S. 595 (1979).
Shortly after the Jones decision-and in apparent reaction to it-the Episcopal Church added Canon I.7.4 (quoted above), which specifies that all church property is held in trust for the national church and its dioceses. This occurred some 25 years before the dispute involving St. James Parish erupted.
The court observed:
Thus, the high court’s discussion in Jones v. Wolf … together with the Episcopal Church’s adoption of Canon I.7.4 in response, strongly supports the conclusion that, once defendants left the general church, the property reverted to the general church. Moreover, Canon I.7.4 is consistent with earlier-enacted canons that, although not using the word “trust,” impose substantial limitations on the local parish’s use of church property and give the higher church authorities substantial authority over that property. For example, permitting a disaffiliating local church to take the property with it when it reaffiliates with a different church is inconsistent with the prohibition of Canon II.6, section 2, against encumbering or alienating local property without the previous consent of higher church authorities. Thus, a strong argument exists that Canon I.7.4 merely codified what had long been implicit ….
In short, St. James Parish agreed from the beginning of its existence to be part of a greater denominational church and to be bound by that greater church’s governing instruments. Those instruments make clear that a local parish owns local church property in trust for the greater church and may use that property only so long as the local church remains part of the greater church. Respect for the First Amendment free exercise rights of persons to enter into a religious association of their choice, as delineated in Jones v. Wolf … requires civil courts to give effect to the provisions and agreements of that religious association
The court noted that its conclusion was bolstered by section 9142 of the California Corporations Code, which states:
(c) No assets of a religious corporation are or shall be deemed to be impressed with any trust, express or implied, statutory or at common law unless one of the following applies …
(2) Unless, and only to the extent that, the articles or bylaws of the corporation, or the governing instruments of a superior religious body or general church of which the corporation is a member, so expressly provide ….
(d) Trusts created by paragraph (2) of subdivision (c) may be amended or dissolved by amendment from time to time to the articles, bylaws, or governing instruments creating the trusts.
The court noted that “this statute appears to be the type of statute the United States Supreme Court had in mind when it approved reliance on ‘provisions of state statutory law governing the holding of property by religious corporations.'”
“Under the neutral-principles approach, the outcome of a church property dispute is not foreordained. At any time before the dispute erupts, the parties can ensure, if they so desire, that the faction loyal to the hierarchical church will retain the church property. They can modify the deeds or the corporate charter to include a right of reversion or trust in favor of the general church. Alternatively, the constitution of the general church can be made to recite an express trust in favor of the denominational church. The burden involved in taking such steps will be minimal. And the civil courts will be bound to give effect to the result indicated by the parties, provided it is embodied in some legally cognizable form.” Jones v. Wolf, 443 U.S. 595 (1979).
The court surveyed cases from other states that involved similar church property disputes within the Episcopal Church and noted that “with near unanimity [they] awarded the disputed property to the general church when a local church disaffiliated itself from that general church.”
“The individual defendants are free to disassociate themselves from [the parish and the Episcopal Church] and to affiliate themselves with another religious denomination. No court can interfere with or control such an exercise of conscience. The problem lies in defendants’ efforts to take the church property with them. This they may not do.”
The defendants asserted that, over the years, St. James Parish “purchased additional parcels of property in its own name, with funds donated exclusively by its members,” and claimed that it would be unjust and contrary to the intent of the members who “acquired, built, improved, maintained, repaired, cared for and used the property for over fifty years,” to cause the local parish to “lose its property simply because it has changed its spiritual affiliation.” The court responded:
The matter is not so clear. We may assume that St. James Parish’s members did what defendants say they did for all this time. But they did it for a local church that was a constituent member of a greater church and that promised to remain so. Did they act over the years intending to contribute to a church that was part of the Episcopal Church or to contribute to St. James Parish even if it later joined a different church? It is impossible to say for sure. Probably different contributors over the years would have had different answers if they had thought about it and were asked. The only intent a secular court can effectively discern is that expressed in legally cognizable documents. In this case, those documents show that the local church agreed and intended to be part of a larger entity and to be bound by the rules and governing documents of that greater entity.
The court concluded that “when defendants disaffiliated from the Episcopal Church, the local church property reverted to the general church …. The individual defendants are free to disassociate themselves from [the parish and the Episcopal Church] and to affiliate themselves with another religious denomination. No court can interfere with or control such an exercise of conscience. The problem lies in defendants’ efforts to take the church property with them. This they may not do.”
Relevance to Church Leaders
What is the relevance of this case to church leaders? Consider the following points:
1. In general. A decision by the California Supreme Court is not binding on any federal or state court in any other state. Nevertheless, the case represents one of the most extended discussions of church property disputes in recent years by a respected state court, and as a result it may be given special consideration by other courts. The impact of the case is doubtless enhanced by the fact that the court unanimously ruled in favor of the Episcopal Church.
2. Judicial resolution of church property disputes-in general. The United States Supreme Court has noted that a state “may adopt any one of various approaches for settling church property disputes so long as it involves no consideration of doctrinal matters, whether the ritual and liturgy of worship or the tenets of faith.” Jones v. Wolf, 443 U.S. 595 (1979). No one approach is prescribed by law. The only requirement is that a state court’s approach to resolving such disputes does not involve the interpretation or application of religious doctrine.
To illustrate, the so-called “departure from doctrine” approach that was used for many years to resolve church property disputes is no longer allowed because it requires civil courts to determine which faction in a church property dispute has departed from church doctrine. Such an inquiry is clearly barred by the First Amendment.
The United States Supreme Court has approved two methods for resolving church property disputes:
- Under the “principle of government” approach (sometimes called the “compulsory deference” approach), “whenever the questions of discipline, or of faith, or ecclesiastical rule, custom, or law have been decided by the highest of these church judicatories to which the matter has been carried, the legal tribunals must accept such decisions as final, and as binding on them, in their application to the case before them.” Watson v. Jones, 80 U.S. (13 Wall.) 679 (1871).
- Under the “neutral principles of law” approach the civil courts “rely upon provisions of state statutory law governing the holding of property by religious corporations, upon language in the deeds conveying the properties in question to the local church corporations, upon the terms of the charters of the corporations, and upon provisions in the constitution of the [national church] pertinent to the ownership and control of church property.” Md. & Va. Churches v. Sharpsburg Church, 396 U.S. 367 (1970).
3. The canons of the Episcopal Church. The United States Supreme Court has explained the neutral principles of law approach as follows:
Through appropriate reversionary clauses and trust provisions, religious societies can specify what is to happen to church property in the event of a particular contingency, or what religious body will determine the ownership in the event of a schism or doctrinal controversy. In this manner, a religious organization can ensure that a dispute over the ownership of church property will be resolved in accord with the desires of the members. Jones v. Wolf, 443 U.S. 595 (1979).
In 1979, shortly after the Jones case was decided, the Episcopal Church responded to the Jones decision by enacting Canon I.7.4 in attempt, in the words of Jones, “through appropriate … trust provisions [to] specify what is to happen to church property in the event of a particular contingency [and] in this manner [to] ensure that a dispute over the ownership of church property will be resolved in accord with the desires of the members.” Canon I.7.4 specifies:
All real and personal property held by or for the benefit of any Parish, Mission or Congregation is held in trust for this Church and the Diocese thereof in which such Parish, Mission or Congregation is located. The existence of this trust, however, shall in no way limit the power and authority of the Parish, Mission or Congregation otherwise existing over such property so long as the particular Parish, Mission or Congregation remains a part of, and subject to, this Church and its Constitution and Canons.
The California Supreme Court concluded that Canon I.7.4 was a legitimate effort by the Episcopal Church to create a mechanism for resolving church property disputes internally. It required no interpretation or application of church doctrine by the civil courts, and used an established “neutral principle of law” (a trust) as the means for resolving property disputes. As a result, the Episcopal Church acted in a way that did not violate the First Amendment.
The court’s ruling will serve as support for the efforts of any denomination to resolve church property disputes internally through the adoption of trust language, reversionary clauses, or any other “neutral principle of law” that can be applied by the civil courts without delving into church doctrine.
4. Disaffiliation not prohibited. The court stressed that a local congregation is free to sever its affiliation with a parent denomination. But this was not the issue in this case. Rather, the issue was whether a congregation that votes to disaffiliate from a parent denomination retains the legal ownership of its property. As the court concluded:
The individual defendants are free to disassociate themselves from [the parish and the Episcopal Church] and to affiliate themselves with another religious denomination. No court can interfere with or control such an exercise of conscience. The problem lies in defendants’ efforts to take the church property with them. This they may not do.
5. Limitations on the neutral principles of law approach. The United States Supreme Court has cautioned:
The neutral-principles method … requires a civil court to examine certain religious documents, such as a church constitution, for language of trust in favor of the general church. In undertaking such an examination, a civil court must take special care to scrutinize the document in purely secular terms, and not to rely on religious precepts in determining whether the document indicates that the parties have intended to create a trust. In addition, there may be cases where the deed, the corporate charter, or the constitution of the general church incorporates religious concepts in the provisions relating to the ownership of property. If in such a case the interpretation of the instruments of ownership would require the civil court to resolve a religious controversy, then the court must defer to the resolution of the doctrinal issue by the authoritative ecclesiastical body.” Jones v. Wolf, 443 U.S. 595 (1979).
6. The dissenting opinion. One justice, while agreeing with the court’s decision in favor of the Episcopal Church, disagreed with its reliance on the neutral principles of law approach. This dissenting justice asserted that “no principle of trust law exists that would allow the unilateral creation of a trust by the declaration of a nonowner of property that the owner of the property is holding it in trust for the nonowner.” Indeed, “if a neutral principle of law approach were applied here, the Episcopal Church might well lose because the deed to the disputed property is in the name of St. James Parish, and the Episcopal Church’s 1979 declaration that the parish was holding the property in trust for the Episcopal Church is of no legal consequence.”
But, the dissenting justice concluded that “under the principle of government approach, the Episcopal Church wins because that method makes the decision of the highest authority of a hierarchical church, here the Episcopal Church, binding on a civil court. This result is constitutional, but only because the dispute involves religious bodies and then only because the principle of government approach, permissible under the First Amendment, allows a state to give unbridled deference to the superior religious body or general church.”
7. Previously acquired properties. The defendants argued that over the years St. James Parish “purchased additional parcels of property in its own name, with funds donated exclusively by its members,” and that it would be unjust and contrary to the intent of the members who, they argue, “acquired, built, improved, maintained, repaired, cared for and used the real and personal property at issue for over fifty years,” to cause the local parish to “lose its property simply because it has changed its spiritual affiliation.” The court disagreed:
The matter is not so clear. We may assume that St. James Parish’s members did what defendants say they did for all this time. But they did it for a local church that was a constituent member of a greater church and that promised to remain so. Did they act over the years intending to contribute to a church that was part of the Episcopal Church or to contribute to St. James Parish even if it later joined a different church? It is impossible to say for sure. Probably different contributors over the years would have had different answers if they had thought about it and were asked. The only intent a secular court can effectively discern is that expressed in legally cognizable documents. In this case, those documents show that the local church agreed and intended to be part of a larger entity and to be tbound by the rules and governing documents of that greater entity.
8. Future proceedings. Do the defendants in this case have any future legal recourse? Decisions by a state’s highest court can be reviewed by the United States Supreme Court if it grants a writ of certiorari-a common law writ issued by a superior court to one of inferior jurisdiction demanding the record of a particular case. This kind of review is rare; the Supreme Court issues writs of certiorari in less than one percent of all petitions for review. The vast majority of petitions are simply denied without comment or explanation.
A petition for a writ of certiorari must be filed with the Supreme Court within 90 days from the date of the entry of the final judgment in the highest state appellate court or 90 days from the denial of a timely filed petition for rehearing.
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