## Facts

- A dispute arose within the Walnut Street (Third) Presbyterian Church in Louisville, Kentucky, splitting the congregation into two factions, each claiming exclusive control of the local church property.
- The church was part of a hierarchical Presbyterian polity with ascending judicatories (Session, Presbytery, Synod, General Assembly).
- Controversy over slavery and church governance led one faction to align with a separate Presbyterian organization that had separated from the national church, while the other remained loyal to the General Assembly.
- Higher church bodies took disciplinary actions that excluded the separating faction’s leadership from the national church.
- The loyal faction filed a federal diversity suit seeking to enjoin the separating faction from taking possession and to secure control of the property consistent with the ecclesiastical determinations.
- The federal circuit court enjoined the separating faction and recognized the loyal faction’s right to control the property; the separating faction appealed.

## Issues

1. Whether pending state-court proceedings and an unexecuted state-court order concerning possession barred the federal court from entertaining a later diversity suit and issuing an injunction.
2. Whether, in a hierarchical church, civil courts must treat as binding the decisions of the highest church tribunal on matters of faith, discipline, and ecclesiastical governance when those decisions bear on church property rights.

## Decision

- The Court held the federal suit was not barred by the pending state litigation because the later action sought distinct relief concerning the fiduciary character of possession and related trust obligations, not merely the same claim for possession.
- The Court held that in hierarchical churches, civil courts must accept as final the determinations of the highest competent ecclesiastical tribunal on questions of discipline, faith, or ecclesiastical rule, custom, or law.
- Applying that rule, the Court affirmed the decree for the faction loyal to the General Assembly and against the faction that had affiliated with a separate ecclesiastical body.

## Legal Principles

- A prior pending suit defeats a later suit in concurrent jurisdiction only when the parties, claims, and requested relief are sufficiently identical that the first judgment would operate as res judicata in the second.
- Civil courts may not adjudicate the truth or falsity of religious doctrine and should avoid resolving property disputes by deciding theological controversies.
- Church property disputes generally fall into: (1) express trusts dedicated to specific doctrine (courts enforce the trust), (2) independent/congregational churches (property rights follow ordinary rules for voluntary associations, often majority rule), and (3) hierarchical churches (civil courts defer to the highest church judicatory on ecclesiastical questions).
- When a local congregation is subordinate within a hierarchical structure, and the highest church tribunal has decided matters of discipline or governance relevant to the dispute, civil courts must apply that determination when resolving the property controversy.

## Conclusion

The Court affirmed an injunction awarding control of church property to the faction recognized by the hierarchical church’s highest authorities, holding that civil courts must not reexamine ecclesiastical decisions on faith, discipline, or governance and must treat those determinations as binding in resolving church property disputes within hierarchical denominations.


Watson v. Jones, 80 U.S. (13 Wall.) 679 (1871)