Court ruled a Bank Account Established by a Religious Leader to Assist the Poor Belonged to the Organization He Founded

Years ago, $3 million was placed in a bank account entitled "The Honorable Elijah Muhammad's

Years ago, $3 million was placed in a bank account entitled "The Honorable Elijah Muhammad's Poor Fund Account." Elijah Muhammad was the leader of a religious organization known as the Nation of Islam. Following his death in 1975, the bank transferred the funds to a new account in the name of the Nation of Islam, thinking that the poor fund account belonged to the religious organization rather than to Elijah Muhammad personally.

Several years later, the estate of Elijah Muhammad sought to recover the funds from the bank on the theory that the account had been the personal property of Elijah Muhammad rather than of the religious organization. The court concluded that the account belonged to the religious organization rather than to Elijah Muhammad personally, since (1) donations from members of the Nation of Islam constituted an overwhelming portion of the money deposited in the poor fund account, and (2) donors to the poor fund account were informed that their donations would be used primarily to "see to it that the poor and needy of our nation are looked after." Donors were also advised that contributions to the poor fund account were "income tax deductible."

Under these facts, the court concluded that "the funds in the poor fund account were solicited upon the representations that the money would be used to benefit the [religious organization] and that the believers, in making donations, intended their money to be used for that purpose." Under these circumstances, Elijah Muhammad could not be deemed "the equitable owner of the poor fund account."

The court further observed that "where funds are solicited to benefit a religious organization, we believe that basic principles of equity and fair dealing should preclude the use of those funds to benefit the personal estate of the religious leader." This is so even if some donors made contributions to benefit Elijah Muhammad personally, since "contributions to religious leaders for their support are considered contributions for the benefit of the religious organization and may qualify for a charitable deduction." In re Estate of Muhammad, 520 N.E.2d 795 (Ill. App. 1987)

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