62 N.Y.2d 110 (1984)

Civil courts can resolve church property disputes by applying neutral principles of law, examining deeds, charters, and state statutes without delving into religious doctrine.

Summary

First Presbyterian Church of Schenectady (First Church) sued The United Presbyterian Church in the United States of America (UPCUSA) after withdrawing from the denomination due to disagreements over UPCUSA’s financial support of certain political groups. First Church sought a declaration of independence and an injunction to prevent UPCUSA from interfering with its property. The New York Court of Appeals held that civil courts *can* resolve such disputes using “neutral principles of law,” focusing on property ownership documents rather than religious doctrine. The court found in favor of First Church, allowing it to retain control of its property.

Facts

First Church, organized in 1760 and incorporated in 1803, became a member of UPCUSA’s predecessor in 1789.
In the 1970s, the congregation expressed discontent with UPCUSA, particularly regarding its funding of radical groups.
First Church requested dismissal to another denomination, but the Presbytery of Albany denied the request and appointed an administrative commission to investigate First Church’s activities.
In January 1977, First Church voted to sever ties with UPCUSA and retain its property.

Procedural History

First Church sued UPCUSA seeking a declaration of its right to withdraw and an injunction against interference with its property.
The trial court granted the injunction but denied declaratory relief.
The Appellate Division reversed the injunction, dismissed the complaint, and granted UPCUSA’s counterclaim, relying on deference to ecclesiastical authority.
The New York Court of Appeals reversed the Appellate Division’s order regarding the injunction, reinstating the trial court’s original judgment (granting the injunction in favor of First Presbyterian Church).

Issue(s)

Whether a civil court can resolve a church property dispute between a local church and its hierarchical denomination, when the local church has withdrawn from the denomination, without violating the First Amendment’s prohibition against entanglement in religious matters.

Holding

Yes, because the court can apply neutral principles of law to resolve the property dispute without interpreting religious doctrine.

Court’s Reasoning

The Court of Appeals adopted the “neutral principles of law” approach for resolving church property disputes, as endorsed by the U.S. Supreme Court in Jones v. Wolf. This approach involves examining deeds, local church charters, state statutes, and the general church’s constitution, focusing on objective evidence of intent regarding property ownership. The court emphasized that it must scrutinize these documents in purely secular terms, avoiding reliance on religious precepts.

The court found that First Church held record title to the property, the deeds contained no forfeiture or reversion clauses, and state law (Religious Corporations Law) did not apply due to First Church’s pre-1828 incorporation. While the UPCUSA’s Book of Order contained provisions about church governance, it lacked express trust language favoring the UPCUSA. The court stated that any inquiry into the meaning of provisions within the Book of Order by a court is constitutionally foreclosed because it would require the court to choose between the insurgent Session and the commission or “replacement Session.” The Court rejected the argument for an implied trust, noting that First Church acquired the property independently and took no action indicating an intent to create a trust. The court quoted Presbyterian Church v. Hull Church, stating that “the State has a legitimate interest in resolving property disputes, and * * * a civil court is a proper forum for that resolution”.

The court reasoned that applying neutral principles avoids entanglement in religious controversies and allows the state to protect its interest in securing property titles. The court also noted the preference for neutral principles over deference, as the deference approach assumes local churches relinquish control to hierarchical bodies, frustrating the intent of some local churches and potentially violating the free exercise clause. The court states “[i]n applying neutral principles, the focus is on the language of the deeds, the terms of the local church charter, the State statutes governing the holding of church property, and the provisions in the constitution of the general church concerning the ownership and control of church property”.