Rizzuto v. Rematt
273 Ill. App. 3d 447, 653 N.E.2d 34, 210 Ill. Dec. 447 (1995)
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Rule of Law:
Under the First Amendment's ecclesiastical abstention doctrine, civil courts lack jurisdiction to resolve internal disputes of a hierarchical church concerning its governance, financial management, and leadership, even when framed as a secular claim like breach of fiduciary duty involving church property.
Facts:
- The North American Old Roman Catholic Church is a hierarchical religious entity incorporated in Illinois in 1919.
- A 1919 Common Law Trust agreement governs all Church property and grants a sole trustee, the Archbishop, plenary power to manage all church business and property according to his own judgment.
- Theodore J. Rematt is the current Archbishop and sole trustee of the Church.
- Plaintiffs, including Andrew Rizzuto, are parishioners and beneficiaries of the Church's trust.
- Rematt unilaterally decided to secure a $300,000 mortgage on the Church's real property assets without the approval of the parishioners.
- Plaintiffs allege that Rematt has administered the Church trust for his personal benefit and has refused to provide them with a satisfactory accounting of the trust's assets.
Procedural Posture:
- Andrew Rizzuto and other parishioners (Plaintiffs) filed a complaint in an Illinois trial court against Theodore J. Rematt (Defendant), seeking an injunction, a constructive trust, and an accounting.
- Plaintiffs filed a motion for substitution of judge, which the trial court denied.
- The trial court denied Plaintiffs' requests for injunctive relief.
- The trial court granted Defendant's motion to dismiss Plaintiffs' first amended complaint.
- Plaintiffs (appellants) appealed the trial court's dismissal to the Appellate Court of Illinois.
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Issue:
May a civil court intervene in a dispute over the financial management and leadership of a hierarchical church when parishioners allege a breach of fiduciary duty by the church's sole trustee?
Opinions:
Majority - Justice Rizzi
No. A civil court may not intervene because such matters are beyond the realm of judicial jurisdiction. The First Amendment prohibits courts from interfering with the internal governance and ecclesiastical polity of a hierarchical church. The plaintiffs are asking the court to substitute its judgment for that of the trustee, supervise the church's financial affairs, and interfere with its leadership succession. These are fundamentally religious disputes, not secular ones. The Church's own governing documents, specifically the 1919 Trust agreement, grant the trustee sole and plenary control over all property and financial decisions. The mere assertion of a property right is insufficient to invest a civil court with jurisdiction over what is essentially a religious controversy.
Analysis:
This decision reinforces the ecclesiastical abstention doctrine, which creates a high barrier for litigants seeking court intervention in the internal affairs of hierarchical religious organizations. It demonstrates that courts will look past the labels of secular claims, such as breach of fiduciary duty or property disputes, to determine the true nature of the controversy. The ruling solidifies the principle that if resolving a claim requires a court to interpret religious doctrine, polity, or governance structures, the court must abstain from exercising jurisdiction. This precedent makes it significantly more difficult for dissident members of hierarchical churches to use civil courts to challenge the financial or administrative decisions of their leadership.
