Presbyterian Church v. Hull Church (1969)
Supreme Court Decisions on Religious Liberty
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Background Information
Two Presbyterian churches in Savannah, Georgia (Hull Memorial Presbyterian Church and Eastern Heights Presbyterian Church) wanted to withdraw from the control of the U.S. Presbyterian Church. According to the congregations in these two churches, the national church leadership had grown to liberal and was straying from the original doctrines upon which their faith was based.
The local churches began proceedings to separate from the denomination but also keep their church property. The General Assembly of the Presbyterian Church ruled that the congregations were no longer entitled to retain the church property, but the state of Georgia had a law dealing with such controversies.
The principle aspect of this law was a "departure from doctrine" clause - if a party in a conflict could convince a jury that the other party had departed from traditional doctrine, then the party which had remained true to tradition could keep the church property.
The Superior Court found for the local churches because it decided that the implied trust between the local and national churches was terminated because of the latter's substantial departure from its original doctrines.
Court Decision
With the majority decision written by Justice Brennan, the Court unanimously (9-0) ruled that the Superior Court overstepped its constitutional powers by involving itself in this dispute and that the Georgia law was unconstitutional for giving juries the right to make decisions in theological disputes. Justice Brennan wrote in majority decision:
But First Amendment values are plainly jeopardized when church property litigation is made to turn on the ressolution by civil courts of controversies over religious doctrine and practice. If civil courts undertake to resolve such controversies in order to adjudicate the property dispute, the hazards are ever present of inhibiting the free development of religious doctrine and of implicating secular interests in matters of purely ecclesiastical concern.
In an earlier Court Decision (Watson v. Jones) the Supreme Court had ruled that civil courts aer not permitted rule on ecclesiastical questions - but by deciding that the U.S. Presbyterian Church had strayed from its original doctrines, the Superior Court decided which beliefs were "essential" to the faith and thus went against the Watson precedent. It should be left to the people involved to decide which tenants were central to their religious beliefs, not any agency or arm of the government.
Significance
The Supreme Court decided that it is unconstitutional for any courts to decide which beliefs are essential to any religious group. Thus, they continued the legal tradition that the government may not get involved in essentially theological disputes.
At the same time, the Court reaffirmed its power to involve itself in making decisions relating to church property so long it is done on "neutral principles of law." For example, church charters or denominational rules could include language that specifies the conditions under which property ownership would or would not revert to local church organizations.
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