Presbyterian Church v. Mary Elizabeth Blue Hull Memorial Presbyterian Church (1969)

Presbyterian Church v. Mary Elizabeth Blue Hull Memorial Presbyterian Church (1969)

This case followed inexorably from the Watson-Kedroff line of cases, and its reasoning is reflected in the Serbian Orthodox case decided a decade later. A schism in the Presbyterian Church led to a dispute in which the schismatic group claimed to be the true church entitled to church assets because the original church had departed from religious doctrine and no longer was a true Presbyterian Church.

The Supreme Court unanimously rejected that effort, ruling that courts have no power to determine religious dogma or doctrine and thus could not adjudicate the claims of the dissident group.

The Court opined: “First Amendment values are plainly jeopardized when church property litigation is made to turn on the resolution by civil courts of controversies over religious doctrine and practice. If civil courts undertake to resolve such controversies in order to adjudicate the property dispute, the hazards are ever present of inhibiting the free development of religious doctrine and of implicating secular interests in matters of purely ecclesiastical concern.”

This case is an essential element in the fabric of religious liberty cases in which courts avoid interference in ecclesiastical issues of doctrine, faith or membership.

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