Key point 6-03.1. Church members generally have no right to inspect church records unless such a right is conferred by state nonprofit corporation law, a church's charter or bylaws, state securities law (if the church has issued securities), or a subpoena. Church records enjoy no privilege against disclosure, with the exception of documents that are protected by the clergy-penitent privilege under state law.
A New York court ruled that a member had a legal right to inspect church records on the basis of a provision in the not-for-profit corporation law.
A church member requested permission to inspect certain books and records of his church for the years 1997 to present. He relied on the following section of the New York Not-For-Profit Corporation Law (under which the church was incorporated):
Upon the written request of any person who shall have been a member of record for at least six ...