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Watson v. Jones

80 (13 Wall.) U.S. 679, 20 L. Ed. 666 (1872)

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Watson v. Jones

United States Supreme Court

80 (13 Wall.) U.S. 679, 20 L. Ed. 666 (1872)

Facts

In 1853 the Walnut Street Presbyterian Church (the church) purchased property. At the outbreak of the Civil War, the church experienced a schism between proslavery and antislavery members. The majority of the church’s leadership was proslavery, and the majority of the congregation was antislavery. Both sides of the division believed they should retain the church property. The antislavery elders of the church filed a lawsuit in state court seeking a change in church leadership. The Louisville Chancery Court added additional antislavery elders to the leadership of the church but noted that the church was ultimately under the regulations of the Presbyterian Church in the United States of America (PCUSA). The Kentucky Court of Appeals reversed the Chancery Court’s decision to add the antislavery elders to the leadership, citing its belief that the PCUSA was subject to secular law that it had violated. Meanwhile, the proslavery leaders left the church but wanted to retain the church property for their own uses. Slavery also divided the leadership of the PCUSA. The hierarchy of the Presbyterian church placed churches at the bottom, the local presbytery over the individual churches, the local synod over the presbytery, and the General Assembly of the PCUSA at top. The General Assembly took an antislavery stance, which divided the Louisville Presbytery and the Synod of Kentucky. Eventually, the proslavery factions were kicked out of the PCUSA. The antislavery faction of the church filed a lawsuit in federal court arguing that the proslavery faction was attempting to take unlawful possession of the church building. The United States District Court for the District of Kentucky sided with the antislavery faction, finding that the General Assembly had removed the proslavery faction from the PCUSA. The proslavery faction appealed.

Rule of Law

Issue

Holding and Reasoning (Miller, J.)

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