Sharpe v. Bonham

Background

Members of a religious group in Nashville called Grace Church, who were citizens of states other than Tennessee, sued the pastor, elders, and three trustees of a local Grace Cumberland Presbyterian Church. The dispute grew out of a consolidation of the Cumberland Presbyterian Church with the Presbyterian Church in the United States of America. The plaintiffs said the union had been legally completed and asked a court to declare that the church property should be held for the congregation that joined the united body.

Reasoning

The local defendants (other than the trustees) argued the trustees should be aligned with the plaintiffs and that the case had been set up to create a federal-court case. The lower court dismissed the suit because it treated the trustees as not antagonistic to the plaintiffs and thus on the same side, which left some plaintiffs and defendants as citizens of the same State and the court said it could not hear the case. The Supreme Court compared this dispute to a prior decision about a corporate title holder and explained that the trustees were merely title holders who could be properly named as defendants. The Court said the lower court was wrong to align the trustees with the plaintiffs and reversed the dismissal.

Real world impact

The ruling means a federal court should not be blocked from hearing this kind of church property dispute simply by treating title-holding trustees as if they were on the plaintiffs’ side. The decision is a procedural correction: it reverses dismissal so the underlying dispute about who controls the property can be decided on the merits in the appropriate forum.