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Jones v. Wolf (1979)
Vineville Presbyterian Church was established as a member of the Augusta-Macon Presbytery of the Presbyterian Church in the United States (“PCUS”). In 1973, 164 members of Vineville’s congregation voted to separate from the PCUS; 94 members opposed the resolution. The minority faction brought a class action in state court, seeking declaratory and injunctive orders establishing their right to exclusive possession and use of Vineville’s property. The trial court, relying on Georgia’s “neutral principles of law” approach to church property disputes, found for the majority faction.
The Supreme Court affirmed the ruling. In a 5-to-4 decision written by Justice Harry Blackmun, while acknowledging that the First Amendment severely limits the role civil courts play in resolving property disputes, Justice Blackmun held that Georgia’s approach was constitutional. The neutral principles of law approach required courts to use objective, well-established concepts of trust and property law, leaving courts free from entanglement in religious doctrinal questions, stating, “Most importantly, the First Amendment prohibits civil courts from resolving church property disputes on the basis of religious doctrine and practice.”
