FAMILY FEDERATION FOR WORLD PEACE AND UNIFICATION INTERNATIONAL v. HYUN JIN MOON
129 A.3d 234
| D.C. | 2015Background
- UCI (originally “Unification Church International”), a D.C. nonprofit formed in 1977, held millions in assets donated by Unification Church entities; plaintiffs allege those assets were held in trust for the Church.
- Plaintiffs are three Unification-related entities (including Family Federation and the major Japanese donor) and two ousted former UCI directors; defendants are UCI and five directors led by Hyun Jin (“Preston”) Moon.
- Beginning in 2006–2009 Preston Moon gained control of UCI’s board, ousted two directors, amended the articles (removing explicit references to the Divine Principle and changing the name), and diverted funds to entities he controlled, allegedly self-dealing and breaching fiduciary duties.
- Plaintiffs pleaded four claims: breach of trust, breach of corporate fiduciary duties/ultra vires acts, breach of fiduciary duty as agent (Family Federation), and breach of contract/quasi-contract (Japanese Church).
- At trial-court level, defendants moved to dismiss for lack of personal jurisdiction, lack of standing, failure to state a claim (cross-appeal issues), and the court granted judgment on the pleadings for lack of subject-matter jurisdiction under the First Amendment’s religious-abstention doctrine; appellate court affirmed denial of dismissal on cross-appeal but reversed the Rule 12(c) dismissal and remanded.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Personal jurisdiction over nonresident directors | Directors voluntarily served a D.C. nonprofit that controlled D.C. assets; their acts (e.g., amending articles filed in D.C.) foresee being haled into D.C. court | Asserting jurisdiction over nonresident directors violates due process and invokes fiduciary-shield/Shaffer concerns | Affirmed jurisdiction: facts alleged suffice under D.C. long-arm / due process principles |
| Standing to enforce charitable trust and corporate duties | Plaintiffs (including ousted directors, Family Federation, Japanese Church) have a "special interest" or donor/reversionary/settlor interests to sue | Only the Attorney General or limited parties may enforce charitable trusts; donors generally lack standing after a completed gift | Plaintiffs have special-interest standing and pleaded plausible bases for enforcement; 12(b)(6) dismissal improper |
| Whether claims can be adjudicated without violating the First Amendment (religious abstention) | Claims center on neutral-law doctrines (trust, corporate, contract, agency) and can be resolved without resolving doctrinal matters | Resolution would require interpreting church polity/Divine Principle and thus courts must abstain | Reversed trial court’s dismissal: premature to dismiss on pleadings; neutral-principles adjudication may be possible after development of the record |
| Sufficiency of pleadings (oral trust, agency, restricted gifts) | Complaint alleges oral trust intent, agency relationship between UCI/Family Federation, and restricted gifts by Japanese Church | Allegations implausible or contradicted by corporate documents; lacking required documentary proof | Pleadings sufficiently plausible to survive Rule 12(b)(6); documentary conflicts do not mandate dismissal at pleading stage |
Key Cases Cited
- Daley v. Alpha Kappa Alpha Sorority, Inc., 26 A.3d 723 (D.C. 2011) (long-arm jurisdiction and due-process analysis for nonresident officers of D.C. nonprofit)
- Hooker v. Edes Home, 579 A.2d 608 (D.C. 1990) (standing rules for enforcing charitable trusts and the special-interest exception)
- Shaffer v. Heitner, 433 U.S. 186 (1977) (limits of jurisdiction based on in rem seizure of property)
- Jones v. Wolf, 443 U.S. 595 (1979) (permitting civil courts to resolve church property disputes using neutral principles of law)
- Watson v. Jones, 80 U.S. 679 (1871) (historical principle that civil courts may adjudicate church property and contract disputes)