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Jones v. Wolf

443 U.S. 595 (1979)

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Jones v. Wolf

United States Supreme Court

443 U.S. 595 (1979)

Facts

The Vineville Presbyterian Church (Vineville) of Macon, Georgia, was established in 1904. The church property was deeded to the trustees of Vineville. Vineville was a member church of the Augusta-Macon Presbytery of the Presbyterian Church in the United States (PCUS). The hierarchy of the PCUS places individual churches at the bottom, the presbytery above churches, the synod above the presbytery, and the General Assembly at the top. In 1973 a majority of Vineville’s members voted to leave the PCUS and join another denomination, the Presbyterian Church in America (PCA). The Augusta-Macon Presbytery determined that the minority of Vineville’s membership made up the true congregation and revoked any authority the members of the majority had in the PCUS. The minority group sought relief in federal court, hoping to retain the church property as the continuing members of the PCUS. The federal court dismissed the case for lack of jurisdiction. The minority group brought the case to state court. The trial court used Georgia’s neutral-principles-of-law approach to church-property disputes and ruled in favor of the majority group. The neutral-principles-of-law approach instructed courts to look at deeds, trusts, and the legal title of the property to determine which faction in a church dispute should retain church property. The minority challenged the trial court, arguing that its decision violated the First Amendment by going against the PCUS’s determination. The Georgia Supreme Court upheld the trial court. The minority appealed, arguing that the trial court adopted a presumption of majority control.

Rule of Law

Issue

Holding and Reasoning (Blackmun, J.)

Dissent (Powell, J.)

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