44 Pa. D. & C.5th 106
Pennsylvania Court of Common P...2015Background
- Plaintiffs North American Knanaya Diocese, Inc. (NAKDI) and St. Mary’s Knanaya Church (St. Mary’s) are Pennsylvania nonprofit corporations affiliated with the Malankara Suriyani Knanaya Samudayam (MSKS), part of the Universal Syrian Orthodox Church headed by a Patriarch in Damascus.
- MSKS is governed by a 1952 constitution and a chief metropolitan in India; the North America/Europe region is led by Metropolitan Silvanos Ayub. Plaintiffs claim St. Mary’s falls under Metropolitan Ayub’s jurisdiction.
- A series of competing ecclesiastical directives: the Patriarch issued Apostolic Bull No. E338/11 (limiting interference among metropolitans); Metropolitan Ayub appointed and later imposed a board of receivers at St. Mary’s; the MSKS chief metropolitan and the Patriarch later issued countermanding and reaffirming directives, including Bull No. EI29/14.
- Plaintiffs allege defendants (St. Mary’s officers/members) filed false corporate filings with the PA Department of State to seize control of the church and seek civil declarations (e.g., that Metropolitan Ayub is the highest authority over NAKDI/St. Mary’s) and return of church property.
- Defendants filed preliminary objections arguing the court lacks subject-matter jurisdiction under the ecclesiastical deference doctrine (courts must accept decisions of the highest church authority on matters of discipline, faith, and internal governance).
- The trial court found conflicting and ambiguous directives from the Patriarch and other church authorities on hierarchical authority; because resolving plaintiffs’ claims would require deciding these ecclesiastical questions, the court sustained defendants’ preliminary objections and dismissed the complaint for lack of subject-matter jurisdiction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the court has subject-matter jurisdiction despite church hierarchy disputes | Court can declare Metropolitan Ayub the highest authority and adjudicate corporate/control disputes | Ecclesiastical deference bars civil courts from resolving matters that require deciding church hierarchy, discipline, or internal governance | Court lacks jurisdiction and dismissed the complaint (deference applies) |
| Whether Patriarchal directives and MSKS constitution create justiciable corporate questions | Plaintiffs: corporate claims are civil and separable from ecclesiastical questions | Defendants: the directives and constitution create ambiguous, conflicting hierarchical rules that are ecclesiastical issues | Because resolving control requires interpreting ambiguous ecclesiastical directives, court must defer to church authorities |
| Applicability of Poesnecker precedent to this dispute | Plaintiffs relied on Poesnecker to argue civil court could decide who is highest authority | Defendants: Poesnecker is distinguishable because there the removal was by a non-highest body; here the Patriarch is the highest authority whose conflicting directives trigger deference | Court: Poesnecker is inapplicable; here the Patriarch’s ambiguous/conflicting directives require deference |
| Whether court may order turnover of church property and officers | Plaintiffs seek declarations and return of property/records to recognized officers | Defendants assert such relief would require deciding ecclesiastical authority and is barred by deference | Court refused to grant civil relief because it would entangle the court in ecclesiastical governance issues |
Key Cases Cited
- Watson v. Jones, 80 U.S. 679 (1871) (establishes deference to highest church tribunal on ecclesiastical questions)
- Serbian E. Orthodox Diocese for U.S. of Am. & Canada v. Milivojevich, 426 U.S. 696 (1976) (civil courts must accept decisions of highest church authorities on internal governance)
- Presbytery of Beaver-Butler of United Presbyterian Church in U.S. v. Middlesex Presbyterian Church, 507 Pa. 255, 489 A.2d 1317 (1985) (Pennsylvania follows Watson deference doctrine)
- Poesnecker v. Ricchi, 631 A.2d 1097 (Pa. Cmwlth. 1993) (distinguishable: court analyzed whether decision was made by highest judicatory authority)
- Feingold v. Hendrzak, 15 A.3d 937 (Pa. Super. 2011) (procedural standard for preliminary objections in Pennsylvania)