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Kedroff v. Saint Nicholas Cathedral (1952)

Supreme Court Decisions on Religious Liberty

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Background Information

Because of the communist revolution in Russia and conflicts between the communist-appointed religious leaders and American religious leaders of the Russian Orthodox Church, the New York legislature took sides in a dispute over who controlled a Cathedral of the Russian Orthodox Church in New York City and passed a law that took away control of the church from the Moscow synod and gave it to the a ruling committee called "The Russian Church in America" created by Americans.

The local church was agreed with this action, but naturally the church leadership in the Moscow synod preferred to retain their control of the church. Kerdoff represented a group of parishioners who wanted that control to be returned to the the Moscow synod. According to them, the state of New York had no authority to decide what religious group could control a church.

Court Decision

With the majority opinion written by Justice Reed, the Supreme Court found that neither the Establishment Clause nor the Free Exercise Clause permitted the New York legislature to pass a statute designating which religious group may have control over a church. In the law that gave control over the church to American leadership, the state imposed certain beliefs on the members of the St. Nicholas Cathedral by ruling that the church must:

in all other respects conform to, maintain and follow the faith, doctrine, ritual, communion, discipline, canon law, trends, and usages of the Eastern Confession.

Thus it was found that the New York law violated the Fourteenth Amendment by limiting the parishioners' rights to freely exercise their religion.

Significance

This decision effectively prevents states from passing laws that cause the government to take sides in the internal operations of a church. This continued a precedence that government agencies are prohibited from becoming involved in what are essentially theological disputes. Such involvement will necessarily require the government to support or at least appear to support particular religious doctrines over others - something that is outside their sphere of authority.

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