Schofield v. Superior Court
118 Cal. Rptr. 3d 160
Cal. Ct. App.2010Background
- The petition concerns a purely ecclesiastical dispute about who is the incumbent Bishop of the Diocese of San Joaquin (Schofield vs. Lamb) and whether the diocese remained part of the Episcopal Church.
- Plaintiffs (Episcopal Church, Diocese of San Joaquin, Lamb, and related entities) sought declaratory relief on who holds bishopric and related governance roles.
- The trial court granted summary adjudication in favor of plaintiffs on the first cause of action, concluding Schofield’s actions were ultra vires and Lamb valid as successor bishop.
- Defendants challenged the ruling via a writ of mandate, arguing the first cause of action is an ecclesiastical controversy not subject to civil adjudication.
- The court held the first cause of action is purely ecclesiastical and must be dismissed, while allowing civil resolution of property issues through neutral principles of law.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is the first cause of action an ecclesiastical controversy no civil court may adjudicate? | Schofield or Lamb status is ecclesiastical. | Civil courts may adjudicate property, not church doctrine; status can be resolved domestically. | Yes; the action is ecclesiastical and must be dismissed. |
| May civil courts resolve property issues using neutral principles of law despite ecclesiastical questions? | Neutral principles can resolve property disputes independent of doctrine. | Court should defer to church authorities on doctrine, not resolve ownership. | Civil courts may apply neutral principles to property disputes. |
| Did the trial court err in granting summary adjudication on the first cause of action? | Status dispute should be resolved in civil court. | Action is ecclesiastical and non-justiciable. | Yes; trial court erred in granting summary adjudication on the first cause of action. |
| What governing law applies to church property disputes in California? | Neutral principles of law apply; property transfers examined under civil codes. | Religious governance should resolve doctrinal issues; federal constitutional limits apply. | Neutral principles of law apply to property disputes; doctrine left to internal church processes. |
Key Cases Cited
- Watson v. Jones, 80 U.S. 679 (1871) (establishes noninterference in ecclesiastical disputes about ownership)
- Kedroff v. St. Nicholas Cathedral, 344 U.S. 94 (1952) (First Amendment limits on court involvement in church governance)
- Jones v. Wolf, 443 U.S. 595 (1979) (recognizes internal church decisionmaking on governance matters)
- Episcopal Church Cases, 45 Cal.4th 467 (2009) (adopts neutral principles of law for property disputes between church entities)
- New v. Kroeger, 167 Cal.App.4th 800 (2008) (illustrates application of neutral principles to church property issues)
- Conley v. Roman Catholic Archbishop, 85 Cal.App.4th 1126 (2000) (discusses church property disputes and governance under California law)
- Episcopal Church Cases (citation in text), 45 Cal.4th 467 (2009) (reiterates framework for church property disputes)