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|Watson v. Jones|
|Argued March 9–10, 1871|
Decided April 15, 1872
|Full case name||Watson v. Jones|
|Citations||80 U.S. 679 ( more )|
|Majority||Miller, joined by Chase, Nelson, Swayne, Field, Strong, Bradley|
|Dissent||Clifford, joined by Davis|
Watson v. Jones, 80 U.S. (13 Wall.) 679 (1871), is a United States Supreme Court case. The case was based upon a dispute regarding the Third or Walnut Street Presbyterian Church in Louisville, Kentucky.The Court held that in adjudications of church property disputes, 1) courts cannot rule on the truth or falsity of a religious teaching, 2) where a previous authority structure existed before the dispute, courts should defer to the decision of that structure, and 3) in the absence of such an internal authority structure, courts should defer to the wishes of a majority of the congregation. Because the Walnut Street Presbyterian Church had a clear internal authority structure, the court granted control of the property to that group, even though it was only supported by a minority of the congregation.
The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. Established pursuant to Article III of the U.S. Constitution in 1789, it has original jurisdiction over a narrow range of cases, including suits between two or more states and those involving ambassadors. It also has ultimate appellate jurisdiction over all federal court and state court cases that involve a point of federal constitutional or statutory law. The Court has the power of judicial review, the ability to invalidate a statute for violating a provision of the Constitution or an executive act for being unlawful. However, it may act only within the context of a case in an area of law over which it has jurisdiction. The court may decide cases having political overtones, but it has ruled that it does not have power to decide nonjusticiable political questions.
Louisville is the largest city in the Commonwealth of Kentucky and the 29th most-populous city in the United States. It is one of two cities in Kentucky designated as first-class, the other being Lexington, the state's second-largest city. Louisville is the historical seat and, since 2003, the nominal seat of Jefferson County, located in the northern region of the state, on the border with Indiana.
Kentucky, officially the Commonwealth of Kentucky, is a state located in the east south-central region of the United States. Although styled as the "State of Kentucky" in the law creating it, (because in Kentucky's first constitution, the name state was used) Kentucky is one of four U.S. states constituted as a commonwealth. Originally a part of Virginia, in 1792 Kentucky became the 15th state to join the Union. Kentucky is the 37th most extensive and the 26th most populous of the 50 United States.
The first such case was Watson v. Jones, which was decided on common–law grounds in a diversity action without explicit reliance on the First Amendment. A constitutionalization of the rule was made in Kedroff v. St. Nicholas Cathedral, in which the Court held unconstitutional a state statute that recognized the autonomy and authority of those North American branches of the Russian Orthodox Church which had declared their independence from the general church. Recognizing that Watson v. Jones had been decided on nonconstitutional grounds, the Court thought nonetheless that the opinion “radiates . . . a spirit of freedom for religious organizations, and independence from secular control or manipulation—in short, power to decide for themselves, free from state interference, matters of church government as well as those of faith and doctrine.” The power of civil courts to resolve church property disputes was severely circumscribed, the Court held, because to permit resolution of doctrinal disputes in court was to jeopardize First Amendment values. What a court must do, it was held, is to look at the church rules: if the church is a hierarchical one which reposes determination of ecclesiastical issues in a certain body, the resolution by that body is determinative, while if the church is a congregational one prescribing action by a majority vote, that determination will prevail. On the other hand, a court confronted with a church property dispute could apply “neutral principles of law, developed for use in all property disputes,” when to do so would not require resolution of doctrinal issues. In a later case the Court elaborated on the limits of proper inquiry, holding that an argument over a matter of internal church government, the power to reorganize the dioceses of a hierarchical church in this country, was “at the core of ecclesiastical affairs” and a court could not interpret the church constitution to make an independent determination of the power but must defer to the interpretation of the body authorized to decide.
Canon law is a set of ordinances and regulations made by ecclesiastical authority, for the government of a Christian organization or church and its members. It is the internal ecclesiastical law, or operational policy, governing the Catholic Church, the Eastern Orthodox and Oriental Orthodox churches, and the individual national churches within the Anglican Communion. The way that such church law is legislated, interpreted and at times adjudicated varies widely among these three bodies of churches. In all three traditions, a canon was originally a rule adopted by a church council; these canons formed the foundation of canon law.
Congregationalist polity, or congregational polity, often known as congregationalism, is a system of ecclesiastical polity in which every local church congregation is independent, ecclesiastically sovereign, or "autonomous". Its first articulation in writing is the Cambridge Platform of 1648 in New England. Among those major Protestant Christian traditions that employ congregationalism are those Congregational churches known by the Congregationalist name that descended from the Independent Reformed wing of the Anglo-American Puritan movement of the 17th century, Quakerism, the Baptist churches, as well as the Congregational Methodist Church. More recent generations have witnessed also a growing number of non-denominational churches, which are most often congregationalist in their governance.
An episcopal polity is a hierarchical form of church governance in which the chief local authorities are called bishops. It is the structure used by many of the major Christian Churches and denominations, such as the Roman Catholic, Eastern Orthodox, Oriental Orthodox, Church of the East, Anglican, and Lutheran churches or denominations, and other churches founded independently from these lineages.
The word diocese is derived from the Greek term dioikesis (διοίκησις) meaning "administration". Today, when used in an ecclesiastical sense, it refers to the ecclesiastical district under the jurisdiction of a bishop.
An ecclesiastical court, also called court Christian or court spiritual, is any of certain courts having jurisdiction mainly in spiritual or religious matters. In the Middle Ages these courts had much wider powers in many areas of Europe than before the development of nation states. They were experts in interpreting canon law, a basis of which was the Corpus Juris Civilis of Justinian which is considered the source of the civil law legal tradition.
The United Church of Christ (UCC) is a mainline Protestant Christian denomination based in the United States, with historical confessional roots in the Congregational, Reformed, and Lutheran traditions, and with approximately 4,956 churches and 853,778 members. The United Church of Christ is a historical continuation of the General Council of Congregational Christian churches founded under the influence of New England Pilgrims and Puritans. Moreover, it also subsumed the third largest Reformed group in the country, the German Reformed. The Evangelical and Reformed Church and the General Council of the Congregational Christian Churches united in 1957 to form the UCC. These two denominations, which were themselves the result of earlier unions, had their roots in Congregational, Lutheran, Evangelical, and Reformed denominations. At the end of 2014, the UCC's 5,116 congregations claimed 979,239 members, primarily in the U.S. In 2015, Pew Research estimated that 0.4 percent, or 1 million adult adherents, of the U.S. population self-identify with the United Church of Christ.
The United Free Church of Scotland is a Scottish Presbyterian denomination formed in 1900 by the union of the United Presbyterian Church of Scotland and the majority of the 19th century Free Church of Scotland. The majority of the United Free Church of Scotland united with the Church of Scotland in 1929.
Samuel Freeman Miller was an associate justice of the United States Supreme Court who served from 1862 to 1890. He was a physician and lawyer.
Bannatyne v Overtoun  AC 515, was a protracted legal dispute between the United Free Church of Scotland and the minority of the Free Church who had remained outside of the union.
Ecclesiastical jurisdiction in its primary sense does not signify jurisdiction over ecclesiastics, but jurisdiction exercised by church leaders over other leaders and over the laity.
The Church Patronage (Scotland) Act 1711 or Patronage Act is an Act of the Parliament of Great Britain. The long title of the act is An Act to restore the Patrons to their ancient Rights of presenting Ministers to the Churches vacant in that Part of Great Britain called Scotland. Its purpose was to allow the noble and other Patrons in Scotland to gain control over the Church of Scotland parish churches again, having lost that custom in the so-called Glorious Revolution.
Ecclesiastical polity is the operational and governance structure of a church or of a Christian denomination. It also denotes the ministerial structure of a church and the authority relationships between churches. Polity relates closely to ecclesiology, the study of doctrine and theology relating to church organization.
Arbitration, a form of alternative dispute resolution (ADR), is a way to resolve disputes outside the courts. The dispute will be decided by one or more persons, which renders the "arbitration award". An arbitration award is legally binding on both sides and enforceable in the courts.
The Dennis Canon is a common name used for Title I.7.4 of the Canons of the Episcopal Church in the United States of America.
Walnut Hills United Presbyterian Church is a historic church tower in the Walnut Hills neighborhood of Cincinnati, Ohio, United States. The last remnant of a landmark church building, it was designed by a leading Cincinnati architect and built in the 1880s. Although named a historic site a century after its construction, the building was mostly destroyed after extensive neglect caused restoration to become prohibitively expensive.
Trusteeism and the trustee system are practices and institutions within certain parishes of the Catholic Church in the United States, under which laypersons participate in the administration of Ecclesiastical Property. When laypersons are among the trustees, the Church seeks agreement with the civil authorities to have the property administered under principles of canon law.
"Appeal as from an abuse" is a legal term applied in the canon law of the Roman Catholic Church, meaning originally a legal appeal as recourse to the civil forum (court) against the usurpation by the ecclesiastical forum of the rights of civil jurisdiction. It could mean a recourse to the ecclesiastical forum against the usurpation by the civil forum of the rights of ecclesiastical jurisdiction.
Presbyterian Church v. Hull Church, 393 U.S. 440 (1969), was a United States Supreme Court case involving the secession of two local churches from the parent body Presbyterian Church in the United States because, they claimed, the Church had departed from its original doctrinal tenets. The Court ruled that the state could not pass judgment concerning religious doctrine or church law.
Robert Adam Holliday Lusk was a Reformed Presbyterian or Covenanter minister of the strictest sort, in a century which, according to Presbyterian historian Robert E. Thompson, was marked by increasing relaxation into less stringent manifestations of doctrine and practice amongst all branches of Presbyterianism. His career crossed paths with many prominent ministers and he was involved in numerous ecclesiastical courts at pivotal moments in the history of the Reformed Presbyterian Church. Amongst Reformed Presbyterians, he was an "Old Light," and amongst "Old Lights," he would lay claim to be an "Original Covenanter." He was descended from a long line of Scotch-Irish. The Lusks were people of Scottish descent who, due to both civil and religious persecution, fled Scotland to the northern counties of Ireland. They were Ulster Protestants of the Presbyterian persuasion, a persuasion characterized by fastidious religious observance mixed with an aversion to authoritative persecution. Many of these Lusks settled in America prior to the American Revolutionary War.
Serbian Orthodox Diocese v. Milivojevich, 426 U.S. 696 (1976), is a United States Supreme Court case in which the Court held that the judicial determination of the Illinois Supreme Court violated the First Amendment and Fourteenth Amendments. In matters of dispute within hierarchal religious organizations, the Establishment Clause precludes intervention by civil courts regarding internal disputes of church governance. Per the Establishment Clause, decisions imposed by hierarchal religious organizations are binding in civil courts.
The United States Reports are the official record of the rulings, orders, case tables, in alphabetical order both by the name of the petitioner and by the name of the respondent, and other proceedings of the Supreme Court of the United States. United States Reports, once printed and bound, are the final version of court opinions and cannot be changed. Opinions of the court in each case are prepended with a headnote prepared by the Reporter of Decisions, and any concurring or dissenting opinions are published sequentially. The Court's Publication Office oversees the binding and publication of the volumes of United States Reports, although the actual printing, binding, and publication are performed by private firms under contract with the United States Government Publishing Office.
The Reporter of Decisions of the Supreme Court of the United States is the official charged with editing and publishing the opinions of the Supreme Court of the United States, both when announced and when they are published in permanent bound volumes of the United States Reports. The Reporter of Decisions is responsible for only the contents of the United States Reports issued by the Government Printing Office, first in preliminary prints and later in the final bound volumes. The Reporter is not responsible for the editorial content of unofficial reports of the Court's decisions, such as the privately published Supreme Court Reporter or Lawyers' Edition.
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