Jones v. Wolf (1978)
- Docket
- 78-91
- Decided
- 1978-01-01
Summary
Question: Did the First Amendment require the district court to defer to the Augusta-Macon Presbytery commission’s ruling that a minority faction constituted the “true congregation” of Vineville Presbyterian Church? Conclusion: No. In a 5-4 decision written by Justice Harry Blackmun, the Court held that the First Amendment did not require Georgia state courts to defer to the Augusta-Macon Presbytery commission’s ruling in the Vineville church property dispute. Justice Blackman examined the history of Georgia’s approach to church property litigation. Georgia eventually arrived at a “neutral principles of law” method for resolving church property disputes. As applied to the PCUS, this required examining the deeds to the properties in question, state statutes dealing with implied trusts, and the Book of Church Order. The trial court would then determine whether there was a basis for a trust in favor of the general church. Here, the trial court did not discover any language in the Book of Church Order implying a trust in favor of the general church. While acknowledging that the First Amendment severely limits the role civil courts play in resolving property disputes, Justice Blackmun held that Georgia’s approach was constitutional. The neutral principles of law approach required courts to use objective, well-established concepts of trust and property law, leaving courts free from entanglement in religious doctrinal questions. While Georgia’s approach was constitutional on its face, Justice Blackmun could not determine from the facts whether Georgia courts applied the method constitutionally. While the respondent argued that Georgia applied a presumptive rule of majority representation -- as opposed to a rule of deference to church governments -- neither the Supreme Court of Georgia nor the trial court explicitly stated that it was using this rule. Consequently, Justice Blackmun remanded the case so that the Supreme Court of Georgia could definitively determine whether this rule was the law of Georgia. Justice Louis Powell dissented, joined by Chief Justice Warren Burger and Justices Potter Stewart and Byron White. He characterized the dispute not as one over the ownership of property but rather over which faction in Vineville’s congregation has the right to control the use of that property. Justice Powell argued that disputes over church property almost invariably arise out of disagreements regarding doctrine and practice. Consequently, state courts should defer to decisions made within the structure of church governments in any case involving an intrachurch dispute, even when the dispute is over church property.