Holy Spirit Assn. for Unification of World Christianity v. Tax Com’n of City of New York, 55 N.Y.2d 512 (1982)

Civil authorities cannot inquire into or classify the content of the doctrine of an ecclesiastical body to determine if it’s organized and conducted exclusively for religious purposes, but must accept the body’s characterization of its beliefs and activities as long as the characterization is made in good faith and is not a sham.

Summary

The Holy Spirit Association for the Unification of World Christianity (Unification Church) applied for a real property tax exemption in New York City. The Tax Commission denied the application, arguing the Church was “threaded with political motives.” The Church initiated an Article 78 proceeding. The Court of Appeals reversed the lower court’s decision upholding the Tax Commission’s denial, holding that civil authorities cannot delve into the content of religious beliefs to determine whether they are religious. As long as the Church asserts that its activities are religious and does so in good faith, the courts must accept that characterization for purposes of tax exemption eligibility. However, the case was remitted to determine if the properties were used exclusively for religious purposes.

Facts

The Unification Church applied for a real property tax exemption for three properties in New York City: its headquarters, a missionary residence, and a maintenance/storage facility. The Tax Commission denied the exemption, concluding that the Church was too involved in political activities. The Church’s doctrine, based on the teachings of Reverend Sun Myung Moon, includes the belief that every temporal sphere (political, cultural, and economic) is a battleground between God and Satan. The Church asserts that its political and economic activities are integral to its religious mission.

Procedural History

The Church initiated an Article 78 proceeding to annul the Tax Commission’s determination. The Supreme Court, New York County, transferred the proceeding to the Appellate Division. The Appellate Division remanded the matter for a hearing by a Special Referee. The Special Referee concluded the Church’s primary purpose is religious, but that the Commission had not acted arbitrarily. The Appellate Division confirmed the report of the Special Referee and the determination of the Commission. The New York Court of Appeals then heard the case.

Issue(s)

Whether the Unification Church, whose beliefs and activities are partly religious, is organized and conducted primarily for religious purposes, entitling it to a tax exemption under New York Real Property Tax Law § 421(1)(a), when its religious doctrine includes political and economic elements.

Holding

No, because civil authorities cannot inquire into or classify the content of the doctrine, dogmas, and teachings held by that body to be integral to its religion but must accept that body’s characterization of its own beliefs and activities and those of its adherents, so long as that characterization is made in good faith and is not sham.

Court’s Reasoning

The court reasoned that civil authorities are limited to two inquiries: (1) Does the religious organization assert that the challenged purposes and activities are religious? and (2) Is that assertion bona fide? Citing Watson v. Jones, the court stated that “[t]he law knows no heresy, and is committed to the support of no dogma, the establishment of no sect.” The court also referenced United States v. Ballard: “Men may believe what they cannot prove. They may not be put to the proof of their religious doctrines or beliefs”. The court found that the Church demonstrated that its political and economic beliefs are integral to its religious doctrine. The court emphasized it is “not the province of civil authorities to indulge in such distillation as to what is to be denominated religious and what political or economic.” The determination of what constitutes their religion belongs to the religious bodies themselves. The Court found the Tax Commission’s determination to be arbitrary and capricious. The case was remitted to determine if the properties were used exclusively for religious purposes.