A New York state court ruled that a church's books and records were subject to government inspection as part of an investigation into alleged wrongdoing in soliciting contributions.
The state attorney general received reports that the church forced residents of its homeless shelter to "panhandle" contributions on the streets in exchange for room, board and 25% of the moneys collected. There also were allegations that most of the contributions were appropriated for the personal benefit of the church's founder. Accordingly, the attorney general issued a subpoena to the church, directing it to make available for inspection its
- books and records,
- leases and deeds,
- minutes of its governing body and the names and addresses of all directors, officers, and trustees, and
- copies of all materials used to solicit contributions. The church refused to respond to this subpoena on the ground that it violated its "religious rights."