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Constitutional Law Keyed to Choper
Jones v. Wolf
Citation:
443 U.S. 595 (1979)Facts
The Vineville Presbyterian Church of Macon, Georgia, was organized in 1904 and incorporated in 1915. The church property was acquired through contributions from local church members, with deeds placing title in the “Vineville Presbyterian Church” or its trustees. The church was established as a member of the Augusta-Macon Presbytery of the Presbyterian Church in the United States (PCUS), which has a hierarchical form of government. In 1973, at a congregational meeting, 164 members voted to separate from the PCUS, while 94 opposed the resolution. The majority immediately informed the PCUS of their action and joined the Presbyterian Church in America. The Augusta-Macon Presbytery appointed a commission that investigated the dispute and issued a ruling declaring the minority faction to be “the true congregation” and withdrawing from the majority faction “all authority to exercise office derived from the PCUS.” The majority did not participate in the commission’s inquiry or appeal its ruling. Georgia courts, applying a “neutral principles of law” approach, examined the deeds, corporate charter, state statutes, and church documents, finding no basis for a trust in favor of the general church, and awarded control to the majority faction.
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