Southeastern Pennsylvania Synod of the Evangelical Lutheran Church in America v. Meena
2011 Pa. Commw. LEXIS 179
| Pa. Commw. Ct. | 2011Background
- Redeemer Lutheran Church is a Pennsylvania nonprofit religious corporation owning church property in Philadelphia.
- Redeemer is part of the ELCA hierarchical structure and subject to Synod and ELCA discipline.
- Synod placed Redeemer under involuntary synodical administration due to diminished finances and attendance, and announced Redeemer’s closure.
- Synod’s administration led to the locking of Redeemer’s doors and control of church property by Synod-appointed trustees.
- Synod filed a civil action for declaratory relief asserting it is trustee of Redeemer’s property and that Redeemer refused to comply with synodical administration.
- Redeemer challenged Synod’s authority, invoking constitutional/bylaw provisions and seeking judicial review of the ecclesiastical decision; the trial court granted summary judgment for Synod and dismissed Redeemer’s counterclaims; Redeemer appealed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether civil courts have jurisdiction under neutral principles or must defer to ecclesiastical decisions. | Redeemer argues the dispute is a property matter resolvable by neutral principles of law. | Synod contends ecclesiastical governance decisions are binding and non-justiciable. | Ecclesiastical deference governs; neutral principles do not apply. |
| Whether Synod’s Section 13.24 bylaw authority to take charge of property is within Synod’s corporate powers. | Redeemer claims Section 13.24 is ultra vires and conflicts with Redeemer’s articles of incorporation. | Synod argues Section 13.24 authorizes such action under its constitution and by-laws. | Section 13.24 is within Synod’s governance functions, and controlling. |
| Whether Redeemer’s Articles of Incorporation restrict Synod’s power to control or convey Redeemer property. | Redeemer asserts Articles limit Synod’s ability to act without Congregation’s consent. | Redeemer is interdependent with Synod/ELCA, subject to their governance; Article II does not override Section 13.24. | redeemer’s arguments fail; hierarchical structure and consent provisions do not negate Synod authority. |
| Whether the trial court properly abstained from reviewing ecclesiastical decisions and applied proper standard of review. | Redeemer maintains neutral principles could determine the issue. | Court should defer to Synod’s highest judicatory decisions. | Trial court’s deferential approach consistent with established doctrine. |
Key Cases Cited
- Serbian Eastern Orthodox Diocese v. Milivojevich, 426 U.S. 696 (U.S. 1976) (deference to ecclesiastical determinations in church governance matters)
- In re: Church of St. James the Less, 585 Pa. 428 (Pa. 2005) (neutral principles applicable when no ecclesiastical questions arise)
- Presbyterian Church v. Mary Elizabeth Blue Hull Memorial Presbyterian Church, 393 U.S. 440 (U.S. 1969) (context for church property disputes and binding ecclesiastical decisions)
- Presbytery of Beaver-Butler v. Midd Middlesex Presbyterian Church, 507 Pa. 255 (Pa. 1985) (neutral principles of law approach for non-ecclesiastical property issues)
- Trinity Lutheran Evangelical Church v. May, 112 Pa.Cmwlth. 557 (Pa. Comm. 1988) (ecclesiastical determinations about viability/closure of congregations are binding)