443 U.S. 595 (1979)
The Vineville Presbyterian Church of Macon, Georgia, was organized in 1904 and first incorporated in 1915.1 Its corporate charter lapsed in 1935 but was revived and renewed in 1939 and remained in effect.2
The church property at 2193 Vineville Avenue was acquired in three separate transactions.3 Conveyances ran to the Trustees of Vineville Presbyterian Church and their successors or simply to the Vineville Presbyterian Church itself. All acquisition funds came from local members.4 Pursuant to congregational resolutions, the church repeatedly borrowed against the property through security deeds issued in the name of the trustees or the church.5
In the year of its organization the Vineville church affiliated with the Augusta-Macon Presbytery of the Presbyterian Church in the United States.6 The PCUS maintained a hierarchical or connectional form of government under its Book of Church Order.7 Initial governance of each local church rested in its Session, subject to review and control by the Presbytery, Synod, and General Assembly.8
On May 27, 1973, at a congregational meeting attended by a quorum of duly enrolled members, 164 members including the pastor voted to separate from the PCUS while 94 members opposed the resolution.9 The majority promptly notified the PCUS of the action and affiliated with the Presbyterian Church in America.10 The minority remained on the rolls for three years but ceased participating in Vineville church affairs and conducted religious activities elsewhere.11
The Augusta-Macon Presbytery appointed a commission to investigate the dispute.12 The commission issued a written ruling declaring the minority faction the true congregation of Vineville Presbyterian Church and withdrawing all authority from the majority faction.13 The majority took no part in the commission proceedings and did not appeal to a higher PCUS tribunal.14
Representatives of the minority first sought relief in federal court, where their complaint was dismissed for lack of jurisdiction.15 They then filed this class action in Georgia state court seeking declaratory and injunctive relief to establish their exclusive right to possess and use the church property as the PCUS-affiliated congregation.16 The trial court applied Georgia's neutral principles of law approach and entered judgment for the majority faction.17 The Supreme Court of Georgia affirmed, and the United States Supreme Court granted certiorari.18
Whether civil courts may resolve a church property dispute arising from a schism in a local congregation affiliated with a hierarchical church by applying neutral principles of law drawn from deeds, charters, and governing documents?19
The neutral-principles approach is consistent with the First and Fourteenth Amendments because it relies exclusively on objective, well-established concepts of trust and property law familiar to lawyers and judges, promising to free civil courts completely from entanglement in questions of religious doctrine, polity, and practice.20
Yes. The Georgia courts examined the deeds to the properties, which conveyed the property to the local church, the state statutes dealing with implied trusts, the corporate charter of the Vineville church, and the provisions of the Book of Church Order, finding no language of trust in favor of the general church.21 The approach allows states to adopt any method of resolving church property disputes so long as it involves no consideration of doctrinal matters.22
Civil courts may resolve church property disputes using neutral principles of law.23
Related opinions on this issue
Joined by The Chief Justice, Mr. Justice Stewart, And Mr. Justice White
Justice Powell dissented on the ground that the neutral-principles approach operates as a restrictive rule of evidence that denies courts relevant information about religious polity.24 He argued that attempting to read church constitutions in purely secular terms promotes confusion rather than understanding.25 Powell further contended that the approach invites civil courts to overturn the authoritative resolution of disputes reached within the church itself.26
Such indirect interference with the resolution of religious disputes is no less proscribed by the First Amendment than direct decision of questions of doctrine and practice.27 He concluded that the proper rule requires civil courts to give effect in all cases to the decisions of the church government agreed upon by the members before the dispute arose.28
Whether the First and Fourteenth Amendments require civil courts to defer to the determination of an ecclesiastical commission of the hierarchical church regarding which faction constitutes the true congregation entitled to control the property?29
The First Amendment does not require compulsory deference to religious authority in resolving church property disputes even where no issue of doctrinal controversy is involved. A rule of compulsory deference would require civil courts to examine the polity and administration of a church to determine which unit of government has ultimate control over church property.30
No. The commission appointed by the Augusta-Macon Presbytery declared that the minority faction constituted the true congregation of Vineville Presbyterian Church and withdrew all authority from the majority faction.31 The Georgia courts instead awarded the property to the majority without deference to that ruling.32 The neutral-principles method obviates entirely the need for an analysis or examination of ecclesiastical polity or doctrine in settling church property disputes.33
The First and Fourteenth Amendments do not require civil courts to defer to the ecclesiastical commission's determination.34
Whether Georgia's neutral principles approach, including any application of a majority-representation presumption to identify the local church, was constitutionally applied on the facts of the Vineville Presbyterian Church schism?35
If Georgia has adopted a presumptive rule of majority representation, this would be consistent with both the neutral-principles analysis and the First Amendment. The rule is defeasible upon a showing that the identity of the local church is to be determined by some other means. However, the Georgia courts did not explicitly state that they were adopting such a rule. There are indications that identifying the faction may involve considerations of religious doctrine and polity.36
No. Neither the trial court nor the Supreme Court of Georgia explicitly stated that it was adopting a presumptive rule of majority representation.37 Georgia law requires that church property be held according to the terms of the church government.38 It also provides that a local church affiliated with a hierarchical religious association is part of the whole body of the general church and is subject to the higher authority of the organization and its laws and regulations.39 Such a determination would appear to require a civil court to pass on questions of religious doctrine and to usurp the function of the commission appointed by the Presbytery.40
The judgment of the Supreme Court of Georgia is therefore vacated and the case is remanded for further proceedings not inconsistent with this opinion.41
Georgia's neutral principles approach was not constitutionally applied on the facts of this case, requiring vacatur and remand.42