New York Law Review

Tag: St. Bartholomew’s Church

  • Rector, Church Wardens & Vestrymen of St. Bartholomew’s Church v. Committee to Preserve St. Bartholomew’s Church, 68 N.Y.2d 71 (1986): Permissible Use of Church Funds

    Rector, Church Wardens & Vestrymen of St. Bartholomew’s Church v. Committee to Preserve St. Bartholomew’s Church, 68 N.Y.2d 71 (1986)

    A religious corporation may use its funds for activities incidental to its support and maintenance, including income-producing activities, as long as the proceeds support the corporation’s spiritual objectives.

    Summary

    This case addresses whether St. Bartholomew’s Church’s use of funds to develop a commercial office tower on its property violates Religious Corporations Law § 5, which requires funds to be used for the “support and maintenance” of the church. The Court of Appeals held that the church’s activities did not violate the statute. The Court reasoned that Religious Corporations Law § 5 permits a church to engage in activities incidental to its maintenance, including efforts to improve its financial condition through real estate development, provided the proceeds are used to support the church’s spiritual objectives, and the trustees act honestly and fairly.

    Facts

    St. Bartholomew’s Church, a designated landmark, sought to construct an office tower on its property through a long-term lease arrangement. The New York City Landmark Preservation Commission repeatedly denied the church a certificate of appropriateness. A group of parishioners challenged the church’s expenditure of funds to contest the landmark designation and pursue the office tower development plan, claiming it violated Religious Corporations Law § 5.

    Procedural History

    The parishioners filed suit seeking a declaratory judgment and an injunction to prevent further expenditure of church funds on the office tower project. The lower courts dismissed the claim. The Court of Appeals affirmed the dismissal, holding that the church’s actions did not violate Religious Corporations Law § 5.

    Issue(s)

    Whether the use of St. Bartholomew’s Church funds to pursue the development of a commercial office tower on church property constitutes a violation of Religious Corporations Law § 5, which requires funds to be used for the “support and maintenance” of the church.

    Holding

    No, because the development plan is incidental to the maintenance and upkeep of the religious corporation as it is designed to improve the financial condition of the church and to support its activities.

    Court’s Reasoning

    The Court reasoned that Religious Corporations Law § 5 provides an orderly method for administering church property and ensuring it is used for the benefit of the religious group. An incorporated church is free to engage in enterprises that are incidental to its maintenance. The court emphasized that a church can invest in income-producing property to preserve its funds and ensure its continued viability, stating that trustees are empowered to administer church property in a way that makes assets more productive to assure the continued viability of the corporation’s spiritual objectives. Any profit-making activities are subject to the limitation that the proceeds must support the lawful purpose of the spiritual church. As long as the profit-seeking activity is reasonably incidental to the church’s support and maintenance, and directed towards meeting the needs of the spiritual church, judicial interference is unwarranted. The court stated, “[w]here, as here, the profit-seeking activity undertaken by the trustees of a religious corporation is reasonably incidental to its support and maintenance, and is directed toward assuring that the needs of the ‘spiritual church’ will be met, there is no occasion for a court’s interference in the process.” The Court deferred to the church members’ determination of the prudence of the investment, finding no evidence that the trustees acted dishonestly or unfairly, or abandoned church purposes for commercial gain.

  • Rector, Church Wardens & Vestrymen of St. Bartholomew’s Church v. Committee to Preserve St. Bartholomew’s Church, 56 N.Y.2d 71 (1982): Estoppel Based on Prior Agreement in Church Dispute

    Rector, Church Wardens & Vestrymen of St. Bartholomew’s Church v. Committee to Preserve St. Bartholomew’s Church, 56 N.Y.2d 71 (1982)

    A party cannot challenge the validity of an election based on procedures they previously agreed to and actively participated in, especially when a court-approved process was followed to resolve a dispute.

    Summary

    A committee of church members sought to invalidate a church election authorizing the sale of church property, arguing that the election procedures violated the law. The church had initially sued the committee regarding the use of a name, and the committee counterclaimed to require a vote on a by-law amendment restricting property sales. Both sides agreed to have a judge resolve disputes concerning the election. The election proceeded under the judge’s guidelines, and the property sale was approved. The Committee then challenged the election based on alleged statutory violations. The New York Court of Appeals held that the Committee was estopped from challenging the election since they agreed to the procedures and participated in the election based on those procedures. The Court emphasized that parties cannot change the rules after being disappointed with the outcome.

    Facts

    St. Bartholomew’s Church sought to sell or lease a portion of its property. A group of parishioners formed the “Committee to Preserve St. Bartholomew’s Church Inc.” to oppose the transaction. The church sued the Committee to enjoin the use of the name and to impress a constructive trust on solicited funds. The Committee counterclaimed, seeking to impress a constructive trust and to compel a special meeting to vote on a by-law amendment requiring member approval for property sales. The church agreed to a letter of intent with a developer, contingent on timely approval of the leasehold. The church then scheduled a vote on the proposed sale.

    Procedural History

    The Supreme Court initially granted a preliminary injunction against the Committee’s name use and later granted summary judgment to the defendants, ordering the church to hold an election on the by-law amendment. The Appellate Division denied a stay but expedited the appeal. Justice Greenfield approved a by-law amendment requiring a vote of the parish for authorization of the disposition of church property. Justice Greenfield vacated the order enjoining the election and set guidelines for voter qualifications. The Appellate Division found no basis for setting aside the election, and granted the Committee leave to appeal.

    Issue(s)

    Whether a party that actively sought and agreed to a court-ordered election procedure can later challenge the election’s validity based on alleged violations of the Religious Corporation Law after being disappointed with the election results.

    Holding

    Yes, because the Committee actively sought the court’s intervention, agreed to abide by the court’s ruling, and participated in the election under the court’s prescribed guidelines. The Committee is estopped from challenging the procedures after the election’s outcome disappointed them.

    Court’s Reasoning

    The Court of Appeals emphasized that the parties had jointly sought Justice Greenfield’s intervention to resolve the election dispute, agreeing to comply with his determination. The election was then conducted according to the procedures prescribed by Justice Greenfield. The Court stated, “In this case it is clear that all parties were mindful of the fact that a determination had to be reached as soon as possible. In order to insure an expeditious resolution of their dispute they agreed to submit the controversy to Justice Greenfield prior to any sale or election and to comply with his determination.” The Committee’s challenge arose only after losing the election. The Court invoked the principle that parties cannot change the rules of the game after being disappointed by the outcome, citing Stevenson v News Syndicate Co., 302 NY 81, 87; Cullen v Naples, 31 NY2d 818, 820; Martin v City of Cohoes, 37 NY2d 162, 165-166. The Court effectively applied a form of equitable estoppel, preventing the Committee from asserting a claim inconsistent with their prior conduct. The court found that “the parties charted their own course and the Committee cannot now seek to change the rules merely because it has been disappointed by the outcome of the election”. There were no dissenting or concurring opinions.