Peters Creek United Presbyterian Church v. Washington Presbytery
90 A.3d 95
| Pa. Commw. Ct. | 2014Background
- Peters Creek United Presbyterian Church (incorporated 1931) amended its bylaws in 2001 to declare it a "particular" congregation of the Presbyterian Church (U.S.A.) (PCUSA) and to make the PCUSA Constitution/Book of Order "obligatory," including the Trust Clause that member-church property is "held in trust" for the PCUSA.
- In 2007 a majority of Peters Creek members voted to disaffiliate from the PCUSA, amend the bylaws to remove PCUSA references, and affiliate with the Evangelical Presbyterian Church (EPC); the minority and the Washington Presbytery contested those acts in consolidated actions in the trial court.
- The trial court granted summary judgment to the Majority, finding no trust in favor of the Presbytery/PCUSA and upholding the November 4, 2007 disaffiliation vote; the Presbytery and Minority appealed.
- The Commonwealth Court addressed (1) whether the civil court must defer to the Presbytery’s ecclesiastical determination of the “True Church,” (2) whether Peters Creek property is held in trust for the PCUSA/Presbytery, and (3) whether the 2007 disaffiliation and bylaw amendments were valid.
- The Court held that ecclesiastical questions about the “True Church” are for the church hierarchy (deference rule) but that property and corporate questions must be resolved under neutral principles of law; it found the 2001 bylaws and conduct manifested intent to create a trust in favor of PCUSA and invalidated the 2007 disaffiliation vote under corporate and charter constraints.
Issues
| Issue | Plaintiffs' Argument | Defendants' Argument | Held |
|---|---|---|---|
| Whether court must enforce Presbytery’s determination of which faction is the “True Church” | Presbytery’s ecclesiastical determination should be binding and resolves property control | Majority: property/corporate questions are for civil courts under neutral principles | Court: defer to Presbytery on purely ecclesiastical question, but that determination does not decide civil property/corporate rights (deference + neutral principles) |
| Whether Peters Creek property is held in trust for PCUSA/Presbytery | Trust exists because 2001 bylaws adopted PCUSA Constitution/Book of Order (including Trust Clause) and conduct (seeking presbytery approvals) show settlor intent | Majority: no formal trust instrument; title never changed; unilateral imposition by denomination invalid | Court: Held trust exists — 2001 bylaws (signed corporate act) + conduct show clear, unambiguous intent to create trust; legal title remains with local corporation as trustee for PCUSA/Presbytery |
| Whether Jones v. Wolf allows denomination to unilaterally create enforceable trust by constitutional language alone | Appellants: Jones permits denominational constitutions to create binding trusts without local consent | Majority: Jones does not abrogate state trust law; local assent or equivalent manifestation required | Court: Jones does not permit unilateral imposition; trust creation governed by ordinary trust law and settlor intent — Jones consistent only where legally cognizable consent/manifestation exists |
| Validity of November 4, 2007 vote to amend bylaws and disaffiliate | Majority: Nonprofit members have statutory power to amend bylaws by majority vote; bylaws allowed amendment subject to law and charter | Minority/Presbytery: 2001 bylaws and 1931 charter made PCUSA Constitution obligatory and limited ability to disaffiliate; vote violated charter, bylaws, and Book of Order | Court: 2007 vote invalid. Charter and preexisting bylaws (incorporating Book of Order) controlled; corporate acts inconsistent with charter/bylaws are void; Peters Creek must act as trustee for PCUSA/Presbytery |
Key Cases Cited
- Jones v. Wolf, 443 U.S. 595 (1979) (establishes neutral-principles alternative to deference in church property disputes)
- Presbyterian Church in the U.S. v. Mary Elizabeth Blue Hull Mem’l Presbyterian Church, 393 U.S. 440 (1969) (courts must avoid resolving doctrinal questions; deference to ecclesiastical tribunals)
- Kedroff v. St. Nicholas Cathedral of Russian Orthodox Church in N. Am., 344 U.S. 94 (1952) (civil interference with hierarchical church governance violates First Amendment)
- Watson v. Jones, 80 U.S. 679 (1872) (early articulation of deference rule to church tribunals)
- Presbytery of Beaver-Butler v. Middlesex Presbyterian Church, 507 Pa. 255 (1985) (Pennsylvania adopts neutral-principles approach; analyzes when trust exists based on settlor intent)
- In re Church of St. James the Less, 585 Pa. 428 (2005) (Pennsylvania Supreme Court: local church held property in trust under adopted denominational canons; charter/bylaws/control analysis)