Jones v. Wolf (1979)
Supreme Court Decisions on Religious Liberty
|
||
|
||
|
||
|
||
Background Information
The facts of this case were almost identical to the case of Presbyterian Church v. Hull Church. A local Presbyterian church (Vineville Presbyterian Church of Macon, Georgia) experienced an internal schism that led to a vote over whether to separate from the national church structure because of alleged changes in the denomination's policies. The majority of members in the local congregation decided to go ahead with a separation and then unite with another denomination. A dispute then ensued over which faction in the congregation had control over the church building itself: the trustees for the local church or the church organization.
The national church sided with the minority in the congregation, calling it the "true congregation". Lower courts ruled that the minority had control of the church by using the "neutral principles of law" test articulated by the Supreme Court in Presbyterian Church. The lower courts sought to settle the dispute by relying upon the language of the deeds, the terms of the church charter, state statutes, and the general church constitution.
Court Decision
With Justice Blackmun writing the majority opinion, the Supreme Court overturned the lower court's decision by a 5-4 vote and the case was ordered for re-argument. The Surpeme Court also reaffirmed the general principle of "neutral principles of law" which can be used to resolve ownership disputes within a church:
The state has an obvious and legitimate interest in the peaceful resolution of property disputes, and in providing a civil forum where the ownership of church property can be determined conclusively. The primary advantages of the neutral principles approach are that it is completely secular in operation, and yet flexible enough to accommodate all forms of religious organization and polity. ...It thereby promises to free civil courts completely from entanglement in questions of religious doctrine... This is not to say that the application of the neutral principles approach is wholly free of difficulty. The neutral principles method... requires a civil court to examine certain religious documents, such as a church constitution... On balance, however, the promise of nonentanglement and neutrality inherent in the neutral principles approach more than compensates for what will be occasional problems in application.
In this case, however, the lower courts did not adequately explain their "neutral" grounds for their decision because this dispute was between two factions of a local church rather than between the church hierarchy and a local church.
Four justices dissented from this decision and argued that civil courts should not rule on any church property disputes whatsoever, regardless of any possible "neutral principles of law" tests which might be used.
Significance
This decision reasserted the government's interest in settling disputes regarding religious property and reaffirmed the idea that only "neutral principles of law" can be used in such instances without causing the government to interfere with anyone's religious liberties.
However, this decision failed to really explain what specific criteria qualify as "neutral" and, hence, should be used. Instead, the Court simply stated that one of these criterion cannot be religious doctrine and that individual courts would have to decide on a case-by-case basis what 'neutral principles' should be used. An unfortunate result of this is that the lower courts have no clear guidance on what they may and may not do; thus, any of their decisions could be easily overturned.
-->