Presbyterian Church In The United States v. Mary Elizabeth Blue Hull Memorial

393 U.S. 440 (1969)

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Nature of the Case

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Facts

D is an association of local Presbyterian churches governed by a hierarchical structure of tribunals which consists of, in ascending order, (1) the Church Session, composed of the elders of the local church; (2) the Presbytery, composed of several churches in a geographical area; (3) the Synod, generally composed of all Presbyteries within a State; and (4) the General Assembly, the highest governing body. P and D got into a dispute over the control of properties used by the local churches, Ps. The membership of Ps determined that D was in violation of that organization's constitution and departures from the doctrine and practice in force at the time of affiliation. Ps withdrew from the general church to reconstitute the local churches as an autonomous Presbyterian organization. D established an Administrative Commission to seek a conciliation. No solution was in sight, so D acknowledged the withdrawal of the local leadership and proceeded to take over Ps' property on behalf of the general church until new local leadership could be appointed. Ps made no effort to appeal the Commission's action to higher church tribunals. Ps filed separate suits in the state courts to enjoin the general church from trespassing on the disputed property, title to which was in the local churches. D moved to dismiss the actions and cross-claimed for injunctive relief in its own behalf on the ground that civil courts were without power to determine whether the general church had departed from its tenets of faith and practice. The case was submitted to the jury on the theory that Georgia law implies a trust of local church property for the benefit of the general church on the sole condition that the general church adhere to its tenets of faith and practice existing at the time of affiliation by the local churches. The jury was instructed to determine whether the actions of the general church 'amount to a fundamental or substantial abandonment of the original tenets and doctrines of the general church, so that the new tenets and doctrines are utterly variant from the purposes for which the general church was founded.' Ps got the verdict and the Supreme Court of Georgia affirmed. The Supreme Court granted certiorari.