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Episcopal Church Cases

45 Cal. 4th 467,198 P.3d 66, 87 Cal. Rptr. 3d 275 (2009)

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Episcopal Church Cases

California Supreme Court
45 Cal. 4th 467,198 P.3d 66, 87 Cal. Rptr. 3d 275 (2009)

Facts

The Protestant Episcopal Church (the general church) (plaintiff) was organized in the United States in the 1700s. The general church was split geographically into dioceses, each governed by a bishop. Each diocese was further split into missions and parishes, which were the individual churches that members regularly attended. In 1947, St. James Parish (the local church) (defendant), which started as a mission a year earlier, became a parish within the Los Angeles Diocese. The local church’s parish application and articles of incorporation, as well as the general church’s constitution and canons, stated that the local church was part of the general church and subject to the general church’s authority and rules. The general church’s canons, as amended in 1979, also stated that, pursuant to a California statute, property held by any parish was held in trust for the general church and that a parish had power and authority over such property only as long as it remained part of the general church. In 1950, the general church deeded the property on which the local church building was located to the local church. Eventually, in the early 2000s, the local church disaffiliated itself from the general church due to a doctrinal dispute. Thereafter, the general church filed suit, claiming ownership of the property.

Rule of Law

Issue

Holding and Reasoning (Chin, J.)

Concurrence/Dissent (Kennard, J.)

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