Presbyterian Church in the United States v. Mary Elizabeth Blue Hull Memorial Presbyterian Church

The Presbyterian Church in the United States (the national church) (defendant) was a national association of local churches led by a governing body called the General Assembly. After a property dispute with the national church, two of the local churches in Savannah, Georgia (plaintiffs), withdrew their membership from the national church to form a separate, autonomous church. The local churches claimed that the national church had violated the national church’s constitution and tenets of the religion. The national church established a commission and agreed to recognize the withdrawal of the two local churches. However, the national church also demanded that the property used by the local churches be returned to the national church. The title to the property was in the names of the local churches. Rather than appealing the commission’s demand to the General Assembly, the local churches filed a lawsuit in the Superior Court of Chatham County to enjoin the national church from trespassing on the property held by the local churches. The local churches argued that under Georgia law there was an implied trust that the property be used for the benefit of the national church only on the condition that the national church did not violate the tenets or practices of the religion. A jury considered whether the national church had fundamentally violated the tenets of the religion and returned a verdict for the local churches. The trial judge enjoined the national church from trespassing on the local churches’ property. The Supreme Court of Georgia affirmed, and the United States Supreme Court granted certiorari to address the First Amendment issues.