Russian Church of Our Lady of Kazan v. Terlecky, 414 N.Y.S.2d 459 (N.Y. 1979)
Civil courts can resolve church property disputes by applying neutral principles of law without delving into religious doctrine, ensuring the free exercise of religion while adjudicating property rights.
Summary
This case concerns a dispute between two factions within the Russian Church of Our Lady of Kazan (Kazan) regarding control of the parish and its properties. One faction sought to remain under the jurisdiction of the Metropolia, while the other attempted to align with the Synod of Bishops. The court held that the property belonged to the faction loyal to the Metropolia, the ecclesiastical body under which Kazan was originally incorporated and operated until the schism. The decision was based on neutral principles of law, recognizing Kazan’s initial and sustained affiliation with the Metropolia, without resolving any underlying religious controversies.
Facts
In 1942, members of the Russian community in Sea Cliff, New York, organized the Russian Church of Our Lady of Kazan under the guidance of Metropolitan Theophilus of the Russian Orthodox Greek Catholic Church of America (the Metropolia). The community committed to following the Metropolia’s statutes. In December 1942, the church incorporated under New York’s Religious Corporations Law, with a rector appointed by Metropolitan Theophilus serving as a trustee. In 1970, a schism occurred, with one faction (the appellants) attempting to secede from the Metropolia and align with the Synod of Bishops of the Russian Orthodox Church Outside Russia.
Procedural History
Two actions were initiated: one by the faction loyal to the Metropolia to enjoin the secessionists (Action No. 1), and another by the secessionists seeking a declaratory judgment validating their actions (Action No. 2). The trial court ruled in favor of the Metropolia faction. The Appellate Division affirmed in Action No. 1 and modified in Action No. 2 to reinstate the complaint and declare the parties’ rights. The New York Court of Appeals then reviewed the case.
Issue(s)
Whether the control of the property of the Russian Church of Our Lady of Kazan should be vested in a group loyal to the Metropolia, under which it was founded, or be given over to a dissident faction seeking to align with the Synod of Bishops.
Holding
Yes, because the Russian Church of Our Lady of Kazan knowingly and voluntarily chose the Metropolia as its governing body at its founding and consistently recognized its authority until the schism; therefore, the property rights belong to the faction that remained loyal to the Metropolia.
Court’s Reasoning
The court emphasized its role was to resolve the property dispute, not to delve into religious doctrine. It relied on the principle that civil courts can apply neutral principles of law to church property disputes without violating the First Amendment. The court noted uncontroverted evidence that Kazan considered itself affiliated with the Metropolia from its organization in 1942 until 1970. The church was incorporated under the Metropolia’s guidance, followed its statutes, and recognized its authority. The court found no evidence of a direct tie to the Synod of Bishops. The court quoted Presbyterian Church v. Hull Church, stating that the First Amendment commands civil courts to decide church property disputes without resolving underlying religious controversies. Because Kazan was incorporated into the Metropolia, the court reasoned that the right to the parish property belonged to the faction that remained loyal to the Metropolia at the time of the schism. The Court stated, “Civil courts do not inhibit free exercise of religion merely by opening their doors to disputes involving church property. And there are neutral principles of law, developed for use in all property disputes, which can be applied without ‘ establishing ’ churches to which property is awarded.”