• Key point: Most courts regard a church’s membership determinations to be a purely ecclesiastical matter beyond the review of the civil courts.
• A Pennsylvania court refused to order church officials to explain why they refused to admit a person as a member. A member of an Episcopal church asked his church to transfer his membership to another Episcopal church pursuant to an established church procedure. The rector of the second church rejected the transfer of membership without explanation. The member filed a lawsuit asking a court to order church officials to “show cause” why he should not be admitted as a member. A trial court dismissed the lawsuit on the ground that the dispute was doctrinal in nature. The member appealed. A state appeals court ruled that the civil courts are bound by the first amendment guaranty of religious freedom to accept the decisions of religious organizations on matters of “discipline, faith, internal organization, and ecclesiastical rule, custom, and law.” On the other hand, the civil courts can intervene in church disputes that do not implicate such concerns. The court concluded that this case, which involved an individual’s right to membership in a church, was the kind of ecclesiastical matter that was beyond the authority of the civil courts to resolve. It observed: “[M]embership in a congregation is purely an ecclesiastical matter subject to the church rules and controlled by the decisions of the appropriate church tribunals in so far as they do not contravene the civil law. The heart of [the member’s] case is that he desires to become a member in [another church]. Accordingly, it is clear that this case involves a purely ecclesiastical matter.” The court quoted with approval from an earlier decision of the Pennsylvania Supreme Court in Presbytery of Beaver-Butler v. Middlesex, 489 A.2d 1317 (Pa. 1985):
[T]he right to practice one’s belief and worship as one chooses is so deep a root of our constitutional culture that a court, even one with the best intentions, ca be no more than a clumsy intruder into the most delicate and sensitive areas of human life. When Caesar enters the Temple to decide what the Temple believes, he can leave behind only his own views. The view of a court as to who are heretics among warring sects is worth nothing, and must count as nothing if our cherished diversity of religious views is to prevail. Gundlach v. Laister, 625 A.2d 706 (Pa. Cmwlth. 1993).
See Also: Selection and Qualifications
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