Church claim (Massachusetts) · Go Syfert
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Church claim in Massachusetts

7 Massachusetts opinions name it 2 courts 1993–2023 1 in the last five years

The cases below were cited by Massachusetts courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (4)

CaseFollowedCited
Watson v. Jonesgreen
scotus · 1872 · cited in 2 Massachusetts opinions naming this issue, 2001–2001
2 sentences

2001A civil court may not exercise jurisdiction over “a matter which concerns theological controversy, church discipline, ecclesiastical government, or the conformity of the members of the church to the standard of morals required of them.” Watson v. Jones, 80 U.S. (13 Wall.) 679, 733 (1872), quoted in Serbian E.

2001The leading Federal case is Watson v. Jones, 80 U.S. (13 Wall.) 679, 733 (1871) (civil court may not exercise jurisdiction over “a matter which concerns theological controversy, church discipline, ecclesiastical government, or the conformity of the members of the church to the standard of morals required of them”).

22
Hiles v. Episcopal Diocese of Massachusettsgreen
mass · 2002 · cited in 1 Massachusetts opinions naming this issue, 2012–2012
1 sentence

2012See, e.g., Hiles v. Episcopal Diocese of Massachusetts, 437 Mass. 505, 517 (2002) (“Moreover, Title IV, Canon 14, §1, provides in part that ‘clergy who have voluntarily sought and accepted ordination in the Church have given their express consent and subjected themselves to the discipline of this Church and may not claim in proceedings under this Title constitutional guarantees afforded citizens in other contexts.’ A minister’s consent to disciplinary proceedings historically has been a prominent reason for courts to decline to exercise jurisdiction over a dispute on First Amendment grounds”).

11
Madsen v. Erwingreen
mass · 1985 · cited in 1 Massachusetts opinions naming this issue, 1996–1996
1 sentence

1996Compare Madsen v. Erwin, 395 Mass. 715, 722-23 (1985) (decision to fire homosexual employee deemed religious where affidavits showed that homosexuality is a deviation from Church’s standard of sexual morality).

11
Guterman v. Ricegreen
ca1 · 1941 · cited in 1 Massachusetts opinions naming this issue, 1993–1993
1 sentence

1993We also reject the Church’s argument based on Guterman v. Rice, 121 F. 2d 251, 253-254 (1st Cir.), cert. denied, 314 U.S. 680 (1941), that the vote to amend the by-laws was ineffective because the vote was taken prior to the effective date of the amendment to the articles of organization. 8 In Guterman , the issue was whether a chattel mortgage was properly recorded, a question which depended on the residency of the domestic corporation for purposes of the chattel mortgage recording act.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Massachusetts. Read the followed side critically anyway.

Also cited on this issue (6)

CaseCitedYears
Eagle Fund, Ltd. v. Sarkans green
massappct · 2005
1 sentence

2023In addition, absence of prejudice, which is not clearly shown here given the state of the property, "even if true, did not make the sanction imposed unreasonable." Eagle Fund, Ltd., 63 Mass. App. Ct. at 86 .7 7 At oral argument, but not in her brief, the defendant argued that the judge, in granting the Church's motion for sanctions "substantially for the reasons set forth in the plaintiff's memorandum in support of its motion," did not adopt all of the arguments in the memorandum.

12023–2023
Parish of the Advent v. Protestant Episcopal Diocese green
mass · 1997
1 sentence

2001When this choice is exercised and ecclesiastical tribunals are created to decide disputes over the government and direction of subordinate bodies, the Constitution requires that civil courts accept their decisions as binding upon them." “The ‘First Amendment prohibits civil courts from intervening in disputes concerning religious doctrine, discipline, faith, or internal organization.’ ” “[C]ivil courts ‘must tread . . . cautiously’ in disputes involving hierarchical churches.” Hiles , quoting Parish of the Advent, 426 Mass. at 284 , quoting Serbian E.

12001–2001
Serbian Eastern Orthodox Diocese for United States and Canada v. Milivojevich green
scotus · 1976
1 sentence

2001Orthodox Diocese, 426 U.S. at 714 .

12001–2001
Antioch Temple, Inc. v. Parekh green
mass · 1981
2 sentences

1993Since the “determination of a church’s structure is a question of fact,” Id. at 862 , citing Wheeler v. Roman Catholic Archdiocese of Boston, 378 Mass 58, 62 n.2, cert. denied, 444 U.S. 899 (1979), we turn to the evidence before the Superior Court judge to review the Church’s claim that his finding was clearly erroneous.

1993Part of the analysis, of course, depends on the “ecclesiastical documents of the individual church and of any larger church organization with which it is associated.” Antioch, supra at 862 .

11993–1993
Jack's Cookie Co. v. United States green
scotus · 1979
1 sentence

1993Since the “determination of a church’s structure is a question of fact,” Id. at 862 , citing Wheeler v. Roman Catholic Archdiocese of Boston, 378 Mass 58, 62 n.2, cert. denied, 444 U.S. 899 (1979), we turn to the evidence before the Superior Court judge to review the Church’s claim that his finding was clearly erroneous.

11993–1993
Mosley v. United States Appliance Corp. neutral
scotus · 1941
1 sentence

1993We also reject the Church’s argument based on Guterman v. Rice, 121 F. 2d 251, 253-254 (1st Cir.), cert. denied, 314 U.S. 680 (1941), that the vote to amend the by-laws was ineffective because the vote was taken prior to the effective date of the amendment to the articles of organization. 8 In Guterman , the issue was whether a chattel mortgage was properly recorded, a question which depended on the residency of the domestic corporation for purposes of the chattel mortgage recording act.

11993–1993

Where else courts name it

TX 68 (1916–2025) OR 36 (1896–2025) IL 20 (1895–2024) NY 20 (1988–2025) CA 14 (1948–2025) FL 13 (1984–2026) WA 13 (1979–2025) OH 8 (1949–2024) OK 8 (1967–2023) MA 7 (1993–2023) GA 7 (1948–2021) AZ 7 (2002–2025) MN 5 (1928–2016) SC 5 (1995–2017) TN 5 (1927–2025) VA 5 (1997–2025) AL 5 (2002–2014) NC 5 (1980–2022) KY 4 (1955–2017) MS 4 (2000–2009) DC 4 (1986–2025) PA 4 (1903–2021) NJ 4 (1978–1996) MO 4 (1967–2024) IA 3 (2012–2023) SD 3 (1948–2012) MD 3 (1996–2003) LA 3 (1989–2016) UT 3 (2021–2026) WV 2 (2017–2017) WI 2 (2001–2024) CO 2 (1996–2020) CT 2 (1998–1998) VT 2 (2013–2014) IN 2 (1958–2019)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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