St. Mary's Knanaya Church, Inc. v. Father E.M. Unnikunju Abraham
1782 C.D. 2016
| Pa. Commw. Ct. | Nov 16, 2017Background
- Two rival factions of St. Mary’s Knanaya Church dispute ownership and control of church property at 701 Byberry Rd., Philadelphia: the Abraham Faction (appellants) and the Chacko Faction (appellees).
- Procedural posture: Chacko filed an eight‑count complaint and a preliminary injunction after allegedly being locked out despite a 2014 Consent Order that provided shared Sunday access; trial court issued an interim Order (Oct. 5, 2016) requiring weekly alternating possession and shared Sunday time slots to preserve the status quo.
- The factions disagree over hierarchical authority: Abraham faction relies on Metropolitan Silvanos Ayub’s appointments; Chacko faction recognizes a different metropolitan and contends the dispute involves fraudulent corporate filings and a challenged property sale.
- Abraham argues civil courts lack subject‑matter jurisdiction under the ecclesiastical deference rule and contends the trial court imposed a worship schedule without a full hearing and without requiring a bond for the injunction.
- Trial court found preliminary injunction elements met to prevent immediate and irreparable harm, restore the prior status quo of shared use, and narrowly tailored the Order pending full resolution; Commonwealth Court affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Subject‑matter jurisdiction under the deference rule | Civil courts lack jurisdiction; scheduling worship is ecclesiastical and requires deference | Dispute concerns corporate filings, deeds, and property rights susceptible to neutral principles of law | Court may issue interim relief; preliminary posture preserved status quo without resolving ecclesiastical ownership question |
| Sufficiency of hearing before issuing injunction | Trial court abused discretion by issuing Order after only one witness and without allowing Abraham to present more evidence | Trial court exercised discretion; it invited additional affidavits/depositions and treated Order as an interim stay | No abuse of discretion; interim order appropriate and parties could have submitted more evidence but appellants appealed instead |
| Requirement of injunction bond (Pa. R.C.P. 1531(b)) | Trial court erred by not requiring plaintiff to post bond | Chacko contends bond unnecessary given contempt/sanctions finding and procedural posture | Bond issue not properly before court: the Order was interim/stay and trial court did not formally dispose of the injunction until later; appellants did not raise bond at hearing |
| Scope of injunction (imposing worship schedule) | Order impermissibly regulates ecclesiastical worship practice | Order narrowly preserved status quo of shared possession and did not resolve doctrinal questions or ownership on merits | Affirmed: interim schedule acceptable to prevent irreparable harm and maintain status quo pending merits resolution |
Key Cases Cited
- Watson v. Jones, 80 U.S. 679 (establishes ecclesiastical deference rule)
- Presbyterian Church in the United States v. Mary Elizabeth Blue Hull Memorial Presbyterian Church, 393 U.S. 440 (neutral principles allow civil courts to resolve property disputes without resolving doctrine)
- Jones v. Wolf, 443 U.S. 595 (limits courts to neutral principles when resolution would not require doctrinal inquiry)
- Presbytery of Beaver‑Butler v. Middlesex Presbyterian Church, 489 A.2d 1317 (Pa. 1985) (explains rationale and application of deference rule in Pennsylvania)
- Southeastern Pennsylvania Synod v. Meena, 19 A.3d 1191 (Pa. Cmwlth. 2011) (when property disputes require review of internal church governance, courts must defer)