A Reversal from the California Court of Appeals in the LA Church Fracas

Posted by Kendall Harmon

A press release received via email:

SANTA ANA, Calif. – June 26, 2007 – A three-judge panel of the California Court of Appeal, Fourth Appellate District, Division Three, today reversed the Orange County Superior Court’s prior ruling that three former Episcopal churches which disaffiliated from the national denomination in 2004 did not forfeit their property. This division of the appellate court broke with nearly thirty years of California church property law, and instead ruled that hierarchical church denominations can take over local church property by simply passing an internal rule – even if the local church is separately incorporated, bought and maintained the property.

In August 2004, St. James Church in Newport Beach, All Saints’ Church in Long Beach, and St. David’s Church in North Hollywood, disassociated from the Episcopal Diocese of Los Angeles and the national Episcopal Church (TEC) because of theological differences, which drew international attention because of similar issues facing the Episcopal Church and the worldwide Anglican Communion.

The appellate court’s ruling returns the lawsuits brought by the Episcopal Diocese of Los Angeles and TEC against the three local churches to The Honorable David Velasquez of Orange County Superior Court. Still at issue is whether the Episcopal Church validly passed an internal rule claiming to hold local church property in trust for itself, and whether that rule applied to the three local churches. St. James, All Saints’ and St. David’s, as the property owners, never agreed to relinquish their property to the Episcopal Church upon ending their affiliation. St. James, All Saints’ and St. David’s have maintained all along that they have the right to use and possess the property they have owned and maintained for decades.

Legal spokesperson, Eric C. Sohlgren, said, “This decision puts one division of the appellate court in direct conflict with other California court of appeal decisions that for almost thirty years have rejected the idea that a court must automatically defer to a church denomination in church property disputes. Under this ruling, any big church which calls itself hierarchical could try to confiscate the property of a local congregation simply by passing an internal rule. That idea offends basic principles of fairness and property ownership. St. James, All Saints’ and St. David’s are seriously evaluating an appeal to the California Supreme Court.”


* * *

A Brief Recap: The Diocese of Los Angeles brought lawsuits against St. James, All Saints and St. David’s Anglican Churches and their volunteer board members in September of 2004. Subsequently, the national Episcopal Church intervened into the lawsuits against the three local churches.

On August 15, 2005, Judge Velasquez ruled in favor of St. James against the complaint brought by the Diocese of Los Angeles. In October 2005, Judge Velasquez issued a similar ruling in favor of All Saints and St. David’s. The Episcopal Diocese of Los Angeles appealed the rulings to the California Court of Appeal.

In August 2005, the Complaint in Intervention filed separately by the national Episcopal Church (“TEC”) was still pending in the Orange County Superior Court.

In Fall 2005, the Court granted the three Churches’ challenges to TEC’s original Complaint in Intervention, but gave TEC an opportunity to amend the Complaint (but only if it could do so in good faith). TEC filed a First Amended Complaint in Intervention, which rehashed many of the church-rule arguments the Court had already rejected in prior rulings. The three local churches filed another challenge (called a demurrer) asking the Court to dismiss the First Amended Complaint without further leave to amend on the ground that even if all of the factual allegations were true, they did not state a legal wrong under California law. TEC also appealed that ruling to the California Court of Appeal.






Filed under: * Anglican - EpiscopalEpiscopal Church (TEC)TEC ConflictsTEC Conflicts: Los Angeles* Culture-WatchLaw & Legal Issues

81 Comments
Posted June 26, 2007 at 7:19 pm [Printer Friendly] [Print w/ comments]



1. Irenaeus wrote:

Uh-oh!

June 26, 7:49 pm | [comment link]
2. Dilbertnomore wrote:

As this decision came down from a three-judge panel, is there an avenue of appeal to the full court membership of that division of the Court of Appeals?

June 26, 8:11 pm | [comment link]
3. Milton wrote:

Still at issue is whether the Episcopal Church validly passed an internal rule claiming to hold local church property in trust for itself, and whether that rule applied to the three local churches.

TEC may find itself in the same position as Pharoh’s army, stuck in the mud and all washed up, if the Dennis Canon is found to be invalid.  May the Lord fight for His people and make it so!

June 26, 8:17 pm | [comment link]
4. freihofercook wrote:

This makes things quite complex.  No one should be under any illusions that this will be easy no matter what the final outcome.  TEC is throwing its considerable resources around in order to scare those who will not give in to the new theological agenda.

June 26, 8:21 pm | [comment link]
5. Irenaeus wrote:

I’ll bet the California Supreme Court will resolve the conflict.

June 26, 8:31 pm | [comment link]
6. AnglicanFirst wrote:

Each negative and disputive legal action by ECUSA only increases it’s negative image among the American public. 

ECUSA’s leadership should be labeled as the “Gang Who Couldn’t Shoot Straight” because they are constantly shooting themselves either in their feet or their posteriors.

An Anglican church is supposed to always strive to be Christ-like in it’s demeanor and to emulate the early disciples and church fathers.  It does that by adhering to Scripture, the creeds, church traditions and the Anglican articles of Faith.

The more and more that ECUSA pursues it’s present course, the more and more it will drive away it’s orthodox, traditional and centrists parishoners.  And the more and more hollow ECUSA will become.

In about ten years, EECUSA will be seen as a political organization composed of ultra- liberal progressive political activists.

It’s activism may place ECUSA in jeopardy of losing it’s tax exempt status, since it will have gone beyond the the bounds of being a tax exempt religious body.

June 26, 8:32 pm | [comment link]
7. Br_er Rabbit wrote:

In about ten years, EECUSA will be seen as a political organization composed of ultra- liberal progressive political activists.

In about ten years, ECUSA—as a religious institution—will no longer be relevant to the national scene.

June 26, 8:34 pm | [comment link]
8. Eric Swensson wrote:

Don’t fret. Read 2 Chronicles 20.

June 26, 8:37 pm | [comment link]
9. Br. Michael wrote:

Well, what is says is that only a fool would want to form a church in TEC.  And what’s settled law anyway.  Lawyers have to earn a living.

June 26, 8:44 pm | [comment link]
10. Brian from T19 wrote:

if the Dennis Canon is found to be invalid

Don’t hold your breath-that is internal to the Church, courts won’t want to touch it

Each negative and disputive legal action by ECUSA only increases it’s negative image among the American public.

Is there an image of TEC among the American public?

June 26, 8:52 pm | [comment link]
11. MarkTXK wrote:

#2:  I don’t know how California courts work, but in the federal system, 3-judge panels are automatically appealable to the Supreme Court of the United States.  It seems logical that California would set up its court system similarly.  At any rate, without reading the case, it seems from reading this article that the Superior Court could still hold that the internal rule was not validly created or applied.  Thus while the rule fashioned by the Court of Appeals would be most unfavorable, the facts found by the Superior Court are much harder to review and could still result in a favorable decision for those who are bold to proclaim the catholic faith.

June 26, 9:00 pm | [comment link]
12. Irenaeus wrote:

Mark: The California Supreme Court will have discretion to take the case.

FWIW, an experienced California litigator told me a couple of decades ago that the California appeals courts do not develop setttled, conflicting bodies of law to nearly the same extent as their federal counterparts.

June 26, 9:29 pm | [comment link]
13. Tom Roberts wrote:

Brian #10
Property rights are not internal to the church and corporations are legal persons in states, whereas ecusa is a ‘foreign’ entity in California. As noted even in this decision, ecusa is at best an intercedant. That makes the Dennis Canon a legal hypothesis for California legal precedent. In this appelate decision, it is a hypothesis which this particular panel chose to uphold.

I would not gloat immoderately until all appeals are exhausted. Or perhaps, all parties are exhausted.

June 26, 9:31 pm | [comment link]
14. AnglicanFirst wrote:

Tom Roberts, certainly not the Tm Roberts whom I knew in junior high school, said,

“I would not gloat immoderately until all appeals are exhausted. Or perhaps, all parties are exhausted. “

Since when is “gloating” a behavior for Christians?

June 26, 9:38 pm | [comment link]
15. angloirish wrote:

I think one can appeal the ruling to the full appeals court in CA. Then the next step is the state Supremes. It is sometimes easy to judge-shop for a favorable three-judge panel. This is more difficult when the full court meets. Surprising ruling, nonetheless, considering California land law. This may well wind up before the SCUSA. We do live in interesting times.

June 26, 9:41 pm | [comment link]
16. this_day wrote:

I’d like to read the opinion and the briefs because this certainly goes against California property and trust law.  The Ca high court might have something to say about it.  As I said on SF, this issue is destined for the Supreme Court of the U.S. whether it’s this particular case or another one that’s in cue or yet to be filed.  The Constitutional issues have to be resolved because the jurisdictions are all over the place on the issue.

June 26, 9:42 pm | [comment link]
17. this_day wrote:

angloirish .. jinx wink

June 26, 9:43 pm | [comment link]
18. taz wrote:

I’m not familiar with California law; so I hope there are some some California lawyers that can weigh in here.  But in the jursidictions in which I practice, the ususal next sep in a situation like this would be a motion for a hearing en banc with the whole appellate court. If this panel’s decision is at odds with established precedent as is being suggested, this might give the parishes another shot at a favorable decision at this level.  If the court refuses to grant the motioin for an en banc hearing; or, does and upholds the panel decision, then the next step would be the California Supreme Court.  Again I’m really out of my depth in as to California law.  But my point is that the case isn’t over yet, and this set back is not necesarily the final word.  Don’t lose heart.

June 26, 10:15 pm | [comment link]
19. Laocoon wrote:

A few years ago the Roman Catholic church in Ontario was facing a potentially devastating lawsuit that could have forced them to divest most of their assets.  I recall one bishop saying (I am paraphrasing) “Well, all we need is a table, a cup, and some books.”  It was refreshing to read that.

Let me urge those of us who are remaining in the TEC to write to 815 and to ++Schori to voice our disapproval.  Why should their be public lawsuits among believers?  Will this change anything?  I don’t have much hope that it will, but it would be a shame to stay silent.

June 26, 10:16 pm | [comment link]
20. Tom Roberts wrote:

#14
In terms of ettiquette, I believe we agree

June 26, 10:17 pm | [comment link]
21. Brian from T19 wrote:

Tom

No gloating here.  I actually am relatively disinterested in the lawsuits, although I do hate to hear the hypocrites beg for money to fight for property and call it “the Lord’s work.”

June 26, 10:30 pm | [comment link]
22. Tom Roberts wrote:

#21
It was easy to confuse your concerns, as stated, with stridency.

June 26, 10:41 pm | [comment link]
23. jimB wrote:

Irenaeus,
No way this will end at the State level.  Whoever looses at the Cal Supream will run to the 9th curcuit and whoever looses there will almost certainly seek cert from the Supream Court. 

FWIW
jimB

June 26, 10:47 pm | [comment link]
24. RevOrganist wrote:

Just imagine…..Judgment Day and standing before the Lord God Almighty….and Bruno is asked, “And the reason you took away the houses of worship from my people was??” ——

June 26, 10:49 pm | [comment link]
25. Tom Roberts wrote:

If Bruno had the courage, he’d cite Judges 6 as a precedent. I doubt if he has such convictions.

June 26, 10:53 pm | [comment link]
26. w.w. wrote:

Here is the opinion, both in Word .doc format and .pdf format.

http://www.courtinfo.ca.gov/opinions/documents/G036096.DOC

http://www.courtinfo.ca.gov/opinions/documents/G036096.PDF

P.J. Sills, Concurring: J. Moore, J. Fybel

My take from a quick scan: These guys want to go back to the past, to pre-Jones v. Wolf (USSP) and Barker (Calif. 1981) days, back to the comfort of pre-neutral principles decisions, when deference to church hierarchies was a given. They belittle the landmark ruling in the St. Luke’s United Methodist case, which said that Calif. corporate law allows a property deed owner (St. Luke’s church) to revoke a trust where a denomination passes a rule claiming jurisdiction over the property. The appeals court in Fresno in 2004 recognized the revocation of the trust by St. Luke’s, allowing it to keep its property, and the California Supreme Court days later in effect let that decision stand. These churches in Southern California MUST find a way to appeal, first to the full court, then to the state high court, if necessary; the panel that made this decision is on quicksand.

A sample of this panel’s disdain for the neutral principles approach:

“The Barker court simply assumed that the Church of Palm Springs decision had been correct in upsetting the stable legal universe that existed in California up until that time in the name of “neutral principles.”

w.w.

June 26, 10:53 pm | [comment link]
27. D. C. Toedt wrote:

w.w. [#26], thanks for the links to the opinion. At first reading, and without having read the briefs or the materials cited by the court, it looks to me like the court did a very thorough and competent job.

The court didn’t “disdain” the neutral-principles approach. It simply held that the appellate courts that had adopted that approach didn’t have authority to do so, in view of the established “church governance” precedent of the California Supreme Court, which was never overruled, and the legislative history of some state legislation.

The discussion starting at page 9 of the PDF file is especially interesting, not least because the court notes that it’s irrelevant whether a church is hierarchical, as long as there’s a highest authority.

See particularly the discussion of the prior Hosrman opinion on page 17: “... it is clear from Horsman that our high court was not engaged in figuring out who was theologically correct in the dispute between the liberals and the radicals within the Church of the United Brethren in Christ. The liberals won, because the principle of government in the Church of the United Brethren in Christ was that the decisions of the General Conference were authoritative, and the General Conference had sided with the liberals.”

Starting at page 37, the court explains in considerable detail how (in its view) the California intermediate appellate courts that announced “neutral principles” law were essentially acting lawlessly (my phrasing) by failing to follow the established “church governance” precedent of the California Supreme Court.

The appellate court awarded the appellants (the diocese) their costs on appeal (p. 77).

I doubt we’ve seen the last of this case.

June 26, 11:38 pm | [comment link]
28. this_day wrote:

D.C. - I just skimmed it too and I have to disagree with you.  This written decision is very typical of what has come out of church property litigation ... it’ pre-supposes a legal conclusion (the property belongs to the denomination) and then contorts and misapplies the law in order to get there.

On page 4, the Court deals with the statute that was enacted after the Baker line of cases, which conflicts with Baker unless a   ‘general church’  has a ‘governing instrument’ that ‘expressly’ provides for a trust against local church property in favor of the general church.  The court then makes the conclusory statement that TEC does have a governing instrument expressely providing for such a trust & therefore determines that the statute does not present a conflict that they have to address. [exactly the opposite of what the lower court found]

To come to such a conclusion, however, the Court is rewriting California trust law.  The Dennis Canon is not a valid trust under California law because there is no express grant by the legal and beneficial owner of the property… yet, the appellate court just validated such a trust.  That is a complete departure from what the California supreme court has held. 

I think the appellate court interpreted the statute incorrectly and in the opposite way in which the statute was intended.  Anyway, the legal discussion is technical and tedious.  My point is I think there is certainly grounds for appeal, and since the court applied statutory law in direct contravention of state supreme court precedent,  it is likely the kind of case that the state supremes would accept.  In that event, I wouldnt bet on this decision being upheld ... at least not that part of it.

June 27, 12:11 am | [comment link]
29. D. C. Toedt wrote:

I dunno, this_day [#28], the court’s analysis of the California trust statute (pp. 50-59 of the PDF) look pretty darned compelling to me, although as I said before I haven’t cite-checked the opinion.

June 27, 12:31 am | [comment link]
30. RevOrganist wrote:

It should be noted that one of the 3 justices is a Roman Catholic.  One might surmise her view lends itself to side with hierarchical law, but she would have had to ignore established California Law.

June 27, 12:35 am | [comment link]
31. RevOrganist wrote:

St. James Vestry has acted to safeguard the property that the people of our parish bought and paid for.  We hold the Title.  NEVER has money come from TEC or diocese to St. James…it has always been the other way.  From the outset we have been ready to walk away for the sake of the Gospel.  That is still an option.  Now is a time for prayerful discernment of God’s Will as to how best further the mission of Christ’s Church.

June 27, 12:42 am | [comment link]
32. Sidney wrote:

The national church has posted an article on this.

http://www.episcopalchurch.org/79901_87321_ENG_HTM.htm

# 30 The Catholic Church is scared that individual parishes will lose property in pedophilia litigation against their dioceses - hence tightening the connection between parish and diocese is actually not in their interest.

June 27, 1:01 am | [comment link]
33. MarkTXK wrote:

The court then makes the conclusory statement that TEC does have a governing instrument expressely providing for such a trust & therefore determines that the statute does not present a conflict that they have to address. [exactly the opposite of what the lower court found]

This is what I was trying to allude to in my first comment above (without knowing or going into California’s trust code).  It seems to me that whether there was a trust created in the first place is a question of both law and fact.  And if the Superior Court found that there is no trust as a matter of fact (I am taking your word on that being the case), it seems incumbent on the Appellate panel to show that finding to be clearly erroneous.  I think you’re right that they presupposed the existence of a trust, here.  On the other hand, it seems that if, as a matter of law, one creates a trust by executing an instrument that acedes to canons that impose a trust, then the question becomes, can one revoke that trust by revoking assent to the canons.  I’m unclear as to whether these issues were presented at trial or clearly addressed by the appellate panel.  It just seems that the panel started with the notion that the property belonged to TEC.  Is this consistent with your line of thinking? 

By the way, I’d appreciate your prayers in studying for the bar exam.  smile

June 27, 1:17 am | [comment link]
34. w.w. wrote:

27. D.C. said:

“...the established “church governance” precedent of the California Supreme Court, which was never overruled,...”

What did the Calif. high court mean when it refused to hear the appeal of the United Methodist Church in the St. Luke’s case? The trial court deferred to the hierarchy’s Book of Discipline and rules, but was overruled by the appeals court, contending that Calif. corporate law trumped the hierarchy’s rules re. disposition of property.

Trial courts in Los Angeles and San Diego relied in part on the St. Luke’s decision to reach their judgments that under corporate law, the departing churches could keep their property. The appeals court in Santa Ana has now said, Nope, the hierarchy prevails over state property and trust law, as “reinterpreted” by the appeals court.

And by the way, the Calif. supreme court itself engages in revisionism in church governance matters when it suits those who sit on it. For example, it ruled that the Catholic Church MUST provide prescription contraceptives in its health program for employees, the church’s long-standing doctrinal-based policy against it notwithstanding. So much for the “precedent” you cite….

w.w.

June 27, 1:27 am | [comment link]
35. Revamundo wrote:

In post #1 Irenaeus wrote: Uh-oh!
Uh-oh! is right friends. You need look no further than the flap over the ‘79 BCP. The parishes that left because they had to stay with the ‘28 couldn’t take property. The court has never gone against the hierarchical structure and canon law in the end, especially in matters of doctrinal differences. The “it is ours, we paid for it” argument will carry no weight at all and really look foolish and petty. If it is time to go then it is time to go with a clean slate.

June 27, 1:29 am | [comment link]
36. w.w. wrote:

#28

You meant Barker, after the Protestant Episcopal Church v. Barker (1981) line of cases. (For those doing searches….)

#35:
You said: “The court has never gone against the hierarchical structure ...”  Sure it has. Witness some of the Barker-cited cases, St. Luke’s United Methodist, others.

w.w.

June 27, 1:47 am | [comment link]
37. this_day wrote:

Mark -

First prayers and peace be with you as you study for the bar exam.

And if the Superior Court found that there is no trust as a matter of fact (I am taking your word on that being the case),


Actually it seems they found a trust was created as a matter of fact and as a matter of law ... the law being the Corporations Code statute which was actually meant to limit, not expand, a general church’s claims of beneficial interests in local church property.

it seems incumbent on the Appellate panel to show that finding to be clearly erroneous.

I believe the standard for review is clearly erroneous but California is quirky so dont quote me on that.

I think you’re right that they presupposed the existence of a trust, here.

I am right. wink

On the other hand, it seems that if, as a matter of law, one creates a trust by executing an instrument that acedes to canons that impose a trust, then the question becomes, can one revoke that trust by revoking assent to the canons.

There was no finding that accession language creates an implied trust.  The court created a new kind of trust which is not supported by California law.  And yes, there are express provisions that if a such a trust is created, it can be revoked.  (precisely what happened in St. James, yet the court ignores it)

I’m unclear as to whether these issues were presented at trial or clearly addressed by the appellate panel. 

The issues were presented at trial and on appeal.

It just seems that the panel started with the notion that the property belonged to TEC.

They did.

Is this consistent with your line of thinking?

Pretty much, with the clarifications I’ve added.

June 27, 2:05 am | [comment link]
38. this_day wrote:

#36 ww - thank you for the correction.  I certainly did mean Barker ...

June 27, 2:06 am | [comment link]
39. this_day wrote:

DC - on pp 50-59 of the pdf, the court does exactly what it says it is prohibited from doing.  To wit, altering common law without any indication of legislative intent to do so.  As the court noted .. the legislation was intended to “fill a void” - there is no indicationt that the legislature intended to alter existing trust or property law. In fact, the intent appears to have been to limit the general church’s claims of beneficial interests in local church property.

Statute provides—No assets of a religious corporation are or shall be impressed with a trust, express or implied, statutory or common law unless .... the articles or bylaws of the corporation or the governing instruments of a superior religious body or general church of which the corporation is a member, expressly provide.

^^  The statute does not say that a trust is created simply by including a trust provision in the general church governing docs. It’s saying that to give effect to a trust provision it must be expressly set out in writing in the governing docs or the corporate docs.  Well, that’s not all it takes to create a trust.  There must also be an expression of intent to create a trust by the donor.  The appellate court just created a new form of trust that requires no expression of donor intent.

That’s my take on it anyway.

June 27, 2:15 am | [comment link]
40. Revamundo wrote:

The Calif. decision effectively overturned Barker. I think what will eventually happen is something similar to this: “A Huntsville, Ala., church can leave the Presbyterian Church (USA) with its property, thanks to the resolution of a lawsuit brought by the church against North Alabama Presbytery. But the settlement comes with a price for Central Presbyterian Church: $250,000 to be paid to the presbytery by the end of 2010 – including $100,000 within the next 30 days, when the agreement officially closes. The settlement, reached May 24 in mediation, ends the property ownership lawsuit that the church brought against the presbytery Jan. 29 in Madison County Circuit Court.
In exchange for its freedom, the church has to:
Secure its $250,000 payment to the presbytery by taking a mortgage on a portion of its property.
Acknowledge that its pastor and session did not follow the PCUSA Book of Order regarding a church’s request for dismissal from the denomination.
In exchange for letting Central Presbyterian Church go – perhaps as early as next month – the presbytery has to:
Relinquish its right, title and interest in the church’s real and personal property.
Agree that neither it, the Synod of Living Waters nor the PCUSA’s Office of the General Assembly will attempt to exercise jurisdiction over the church or anyone representing the church.”

To leave TEC with dignity it will come down to 1) pay for the property or 2) leave the property and start over.

When the whole thing gets to the US Supremes I expect a decision similar to Bennison v Sharp 121 Mich App 705, 329 NW2d 466

June 27, 2:48 am | [comment link]
41. Irenaeus wrote:

Revamundo [#35]: You wrote, “You need look no further than the flap over the ‘79 BCP. The parishes that left because they had to stay with the ‘28 couldn’t take property.”

But the Barker decision let three of four churches keep their property. How can you say they “couldn’t take their property”?

June 27, 3:12 am | [comment link]
42. Milton wrote:

Brian from T19 and anyone else who wants to rejoice (prematurely) over this reversal, consider two comments on this topic at Stand Firm in Faith relevant to my comment toward the beginning of these comments here, pasted below:
————————————————————————————————-
First of all I feel badly for these local churches and I will pray for them.
But it’s certain that this will be appealed and if TEC is lucky the case will get thrown out again on the original grounds and the damage will be limited to California.
If this thing somehow gets into the federal courts it will go to SCOTUS and they will set a precedent which will chill TEC to the bones. It’s clear that TEC effectively passed a religious ruling, the Denis Canon, to effect civil law, the transfer of property. If they believed there was any legal standing for what they claim then the Denis Canon would have been unnecessary. Considering where SCOTUS has been going over the past decades with “neutral principles”, and where many states like CA have been following, the only logical end to these cases is that if a church wishes to claim ownership of property, which is solely a civil matter, they should be required to follow civil rules, such as changing the name on the title, to effect civil results.  If the Denis Canon gets thrown out even at the state supreme level then you may even see “liberal” churches asserting their property rights over TEC to insure they can leave if things change.
TEC may be winning battles on the ground but their Gettysburg is there on the horizon, one wonders if they can still avoid it. There is no winning this “war” for TEC but they can avoid losing if they just stop to consider the carnage.

Posted by Rocks on 06-26-2007 at 10:02 PM [link]
Rocks writes:

If this thing somehow gets into the federal courts it will go to SCOTUS and they will set a precedent which will chill TEC to the bones. It’s clear that TEC effectively passed a religious ruling, the Denis Canon, to effect civil law, the transfer of property. If they believed there was any legal standing for what they claim then the Denis Canon would have been unnecessary.
This is exactly right, based on my limited understanding of the facts of the situation.  Right or wrong, the Denis Canon cannot be enforced by state law because it is an ecclesiological doctrine.

Cheers,

TH

Posted by Tom Head on 06-26-2007 at 10:11 PM [link]
————————————————————————————————-
The law of unintended (by TEC) consequences may take effect.  We shall see.

June 27, 4:58 am | [comment link]
43. RevOrganist wrote:

I am reminded that obedience to the Father led Jesus to the cross.  Why are we surprised then or bewildered when our own journey encounters hardship?  It seems that this is partly God’s method.  That He says concerning men like Paul, “I will show him how great things he must suffer for my sake.”

May we not affirm that the supreme example and proof of this is seen in our Lord, who without distrust or rebellion went uncomplaining to the cross?  Is there anywhere so strong and impressive a Christian evidence as is to be found in trial or suffering or loss bravely and trustfully borne, a heavy cross cheerfully carried, irritation patiently endured?  It has pleased God by this means to put to silence the scoff and the sneer, to touch and turn the hearts of people….not of the sufferers, but of those who saw them.

May God be glorified in what do.

June 27, 6:56 am | [comment link]
44. D. C. Toedt wrote:

This_day [#39] writes:

[O]n pp 50-59 of the pdf, the court does exactly what it says it is prohibited from doing.  To wit, altering common law without any indication of legislative intent to do so.  As the court noted .. the legislation was intended to “fill a void” - there is no indicationt that the legislature intended to alter existing trust or property law. In fact, the intent appears to have been to limit the general church’s claims of beneficial interests in local church property.

This_day, the court’s review of the legislative history of the statute in question seems to have been quite thorough. So unless you’ve got a compelling alternative reading of the legislative history (which you haven’t offered), it’s difficult to accept your above-quoted comment.

But as I said before, I doubt very much we’ve seen the last of this case.

June 27, 7:45 am | [comment link]
45. Br. Michael wrote:

I wonder if this will create a cloud on all Diocesan property so that lending institutions will require TED/815 to sign off on all sales or mortgages?  It would also seem to open up parish property for levy to satisfy judgments against the diocese and TEC itself.

June 27, 8:03 am | [comment link]
46. NancyNH wrote:

JimB wrote:
“Irenaeus, No way this will end at the State level.  Whoever looses at the Cal Supream will run to the 9th curcuit and whoever looses there will almost certainly seek cert from the Supream Court.”

I don’t think the Ninth Circuit is in the picture. While my memory is a little hazy after five years of retirement from being a California legal secretary, I seem to remember the chain of appeal to be: Superior Court, Court of Appeal, Motion for Hearing En Banc, California Supreme Court, U.S. Supreme Court.
The Ninth Circuit is a federal court. These property lawsuits were state suits.

June 27, 8:33 am | [comment link]
47. this_day wrote:

I just read the decision again, paying particular attention to the analysis of the legislative history as well as interpretation of Jones.  I am even further convinced that they completely missed the mark on the legislative intent and it’s almost humorous that the court goes into a lengthy disussion on statutory construction ... emphatically stating that statutes must be construed so as not to alter common law unless there is clear intent to the contrary.  Then the court goes right ahead and does exatly that!  This case creates a whole new way of creating trusts that is completely contrary to California trust law.  It’s really unreal.

More than that the Court mischaracterizes and misapplies the rule of Jones - but I’ll save that for another day wink

June 27, 8:40 am | [comment link]
48. SCVJefe wrote:

Nancy in #48 is right about the chain of appeal.

As to prognosticating where this will end, I tend to think that SCOTUS won’t be in the picture, for the reason that the Court’s precedent explicitly allows states to choose either the hierarchical deference or neutral principles approach.  Unless there is a desire among the current members of the Court to change that policy, or some allegation that the California Supreme Court (assuming it takes and decides the case) has applied its chosen standard wrongly, SCOTUS won’t be involved.

June 27, 8:48 am | [comment link]
49. Jeff in VA wrote:

I think w.w. (#34) has the key question here:

What did the Calif. high court mean when it refused to hear the appeal of the United Methodist Church in the St. Luke’s case?

The California Supreme Court denied certiorari in not only the St. Luke’s case, but also the Church of Palm Springs and Barker cases, which this court says misinterpreted California law.

If those denials of cert. were intended as approval of the more recent rejection of the Watson hierarchial deference approach and an endorsement of the neutral principles approach as the standard in California, this court has it wrong when it tries to go back to hierarchical deference.

Of course, cert. was also denied in Korean United, a contemporary case which went the other way, so maybe the California Supreme Court is just “living into the tension.”

June 27, 9:25 am | [comment link]
50. Phil wrote:

By failing to apply neutral principles to the case – that is, the property law the rest of us have to live under – the court has imposed ECUSA’s ecclesial theology on the losing parishes, in violation of the First Amendment.

June 27, 10:28 am | [comment link]
51. this_day wrote:

You’re exactly right Phil and I wonder why we’ve never seen that argument in these property cases.  This case is a good example of the ourts “establishing” religion.  When the issue is frame in that way - I dont see how the S.Ct.  can refuse review when the time comes.

June 27, 10:41 am | [comment link]
52. Jeff in VA wrote:

Phil (#52) and this_day (#53):

A very interesting analysis, to be sure.  The contrary argument is that the hierarchical deference approach actually protects religious groups from government interference by staying out of intra-church disputes, in much the same manner as the ministerial exception allows religious groups to discriminate in hiring in ways that non-religious groups can’t.  The corollary is that “neutral principles” isn’t in fact neutral, but instead requires civil courts to get into the nitty gritty of not only deeds, etc., but also things like canons and constitutions, and to weigh them all against each other, which (the argument goes) is really hard to do without ruling on doctrine (which everyone agrees American courts can’t do). 

Of course, this is all based on Justice Powell’s premise that members joining the church assent to be bound by all decisions of its highest authority, and I know that argument doesn’t play very well ‘round these here parts.

June 27, 10:49 am | [comment link]
53. Cousin Vinnie wrote:

Courts have plenty of expertise authority for tracing titles and interpreting deeds.  They have less experience, and less authority interpreting church law.  I say leave the courts to the recorded deeds, trusts, liens, easements and licenses.

June 27, 11:25 am | [comment link]
54. Phil wrote:

Jeff, I know the contrary argument you describe usually carries the day, but it’s never been clear to me why an application of neutral principles would entail ruling on doctrine.  Sure, that’s where the plaintiff’s lawyer is going to try to take everybody.  On the other hand, who’s name is on the deed?  Does the parent church claim a trust relationship?  Where’s the evidence of it?  If the evidence is an internal rule, does the parent church have inherent authority to enforce it - that is, is the parish formally incorporated as part of the greater church?  If not, is there other evidence of a contractual relationship between the two parties such that the parish expressly agreed to be bound by an internal rule which takes away rights it would otherwise enjoy under the law?  It seems these questions lead to an answer which is not encumbered by a court interpreting doctrine.  Now, if the parent church wants to answer the last question by saying, yes, they agreed to be bound by our rule because they have to be subject to the bishop under Catholic order, then the court replies, talk to the hand.

This seems analogous to me telling a court I’m allowed to beat my child to within an inch of his life because my religion tells me it’s OK.  ECUSA’s argument is, it doesn’t matter if beating a child is otherwise against the law, because the parent has inherent authority over the child, and, furthermore, the parent’s actions are informed by a religious doctrine, so the court must stay out of the matter.  The argument of the faithful parishes is, no, a child can’t be beaten under any circumstances, because the law applies to religious and secular citizens alike, equally.

June 27, 11:34 am | [comment link]
55. jamesw wrote:

These are lawsuits - they are a risk.  Right now, nobody knows what the California Supreme Court will do.  Speaking as someone whose professional is in the field of legal education, I think the law, courts and court precedent is a big joke.  The fact is, in most significant policy cases, the judges pre-decide what they want the outcome to be and then go back and seek to justify their decisions with facts and law.  I would have thought that California law was well settled after the Supreme Court refused to hear the appeal from a very significant church property case, but I guess not.

In the end, although I do think that the orthodox should fight when reasonable for the property, the end game will not be won by who keeps or loses their properties.  The end game will be won by which group plants more churches.

I have been around TEC a lot and I have seen a great deal of churches for which their property is their millstone - they exist to service their property and their property is their identity.  I recall one church that we tried to look up in the phone book but couldn’t find it listed.  We asked someone about it and they said, “oh, we are listed under “H” for “Historic St. Blah-Blah-Blah”.

If property law does get established such that the Courts are enforcing TEC’s theological view of itself (which I believe to be supremely unconstitutional) as a “heirarchical church”, then I would suggest that orthodox parishes seek heritage status for their buildings before leaving.  Then leave the TEC diocese with an albatross around their necks when you leave.

June 27, 11:42 am | [comment link]
56. Jeff in VA wrote:

Phil (#56), you’ve stated the objections well.  Although I suspect some would object to your analogy to child abuse, your basic point is correct:  the hierarchical method essentially says that religion is different, so churches aren’t bound by the normal rules.  Several commentators have pointed out this distinction (esp. as applied differently between hierarchically and congregationally organized religious groups) as the reason the hierarchical approach should be rejected altogether.  The rejoinder (and there’s always a rejoinder) is “Well, they knew how we were organized when they joined.”  And, of course, the answer is “Well, first of all, we didn’t, because we (usually) joined before you passed the Dennis Canon, and second, our assent (to your authority and to any trust in the property) was premised on you not going and mucking around with doctrine, which you did.”

Round and round.

June 27, 11:42 am | [comment link]
57. Phil wrote:

Yeah, Jeff, I know.  As much as I would like to have these assets deployed for the Church’s ends, and not ECUSA’s; and, while I hesitate to second-guess these good brothers and sisters that have such connections to these sites, I just wonder if we should stop allowing ECUSA to take us round and round.  Israel was told God would provide, and He did; manna isn’t steak, but maybe it’s all we deserve right now.

I hate to “lose” as much as anyone, but that’s the spirit of the age speaking.  Jesus has already won the final victory.

June 27, 11:55 am | [comment link]
58. Dave B wrote:

#57 Jamesw,  “their property is their millstone”  I agree.  I visited the Cathedral in Colone Germany.  Kids use the plaza to skate board in and pee against the church walls giving this great building all the respect due a cow stall.  The up keep is enormous.  God dwells in the hearts of mankind not in “sacred” places.  The early chuch turned the world “upside down” without a cathedral or large stately churchs.  I am begining to think that leaving TEC with the property may be the way to go.  I have reason to believe God is faithful to those that put their trust in him.  Those who gave to TEC in the past are (I hope) with Jesus and propably don’t give a moments thought to some silly building.

June 27, 12:04 pm | [comment link]
59. Phil wrote:

Another thought, Jeff (I know I may be preaching to the choir here).  I would also argue there’s nothing unique about a hierarchical church such that we should defer to its rules in a propoerty case, because it can - if it really has the authority it claims - align its secular affairs with its ecclesiology.

If ECUSA were to say to me, “You have to trust us, because we’re a religious organization,” I would ask: why?  The Roman Catholic Church also claims to be hierarchical, but I don’t have to “trust” it - it did the secular legwork to put its parishes’ deeds in the name of the respective dioceses.  Why didn’t your client do that, Mr. Beers, if it’s allowed to do so?

June 27, 12:36 pm | [comment link]
60. jamesw wrote:

Dave B.:

Some more thoughts on this:

1. TEC has always struck me as being an overly proud denomination, and that pride has typically been expressed in terms of fancy buildings, fancy dressing up, and fancy choirs and music.  Both conservatives and liberals have been guilty of this pride.  Perhaps part of the whole collapse of TEC is connected with this sin.

2. I have had occasion to hear a few Global South bishops speak.  I have little doubt that while they are 100% supportive of the North American orthodox, they probably are rather puzzled at the great attachment we have to material things, and to our church buildings.  They face persecution every day, including their buildings being burnt and their being attacked.

3. Think long-term.  A congregation that is forced through a hard time, and that must start out fresh is more likely to have a pioneering mission-focused DNA instilled in it.  Consider the effects on the new Anglican congregations versus the old TEC.  The new congregation is instilled with a mission-focused DNA and attracts those interested in building a new church.  Where will they be in 20 years?  But the old TEC is left with near empty buildings, aging parishioners, and a seriously declining demographic market share.  Which group would you put money on to be around in 20 years time?

4. Jeff and Phil - I understand the arguments favoring the heirarchical theory - Dale Rye is perhaps the best proponent of that argument.  My problem with that is that no matter how you explain it, the courts are enforcing a church’s theological self-description to defeat the plain meaning of secular property documents.  If a church wishes to be heirarchical, there is nothing preventing them from legally organizing themselves in that way.  What I think is indefensible is using the Constitution to permit a Church to circumvent the secular law so that they can avoid damages in civil cases (e.g. paedophile priests) while retaining control of properties (e.g. TEC).  That seems to me plain wrong.

June 27, 12:39 pm | [comment link]
61. this_day wrote:

Phil:

Another thought, Jeff (I know I may be preaching to the choir here).  I would also argue there’s nothing unique about a hierarchical church such that we should defer to its rules in a propoerty case, because it can - if it really has the authority it claims - align its secular affairs with its ecclesiology.

Which is essentially what Jones held 40 years ago; the ruling has been consistently misinterpreted, however, to allow a national church to create a property interest for itself in land that it doesnt own.

June 27, 12:45 pm | [comment link]
62. this_day wrote:

Make that 30 years ... not 40

June 27, 12:48 pm | [comment link]
63. Jeff in VA wrote:

Phil (#61) and jamesw (#62), I think you’ve both hit nails on heads in terms of equity: the “cake and eat it too” argument works as well for any kind of liability as for sexual misconduct by employees.  If, as some have suggested, TEC structured itself the way it did to avoid being held responsible for accidents, &c. that occur on local parish property, it seems more than a little unfair to give it the benefit of centralized control for the purposes of ownership during a dispute.

June 27, 12:48 pm | [comment link]
64. Jeff in VA wrote:

A little procedural info from Richard Zevnik, a California attorney who attended oral argument (posted in a comment here):

Procedurally, the disaffected congregations have 30 days to petition for rehearing in the Court of Appeal. . . .  When the 30 days expires, the congregations then have 10 days to petition for review in the CA Supreme Court. . . .  Review by CA Supreme Court is discretionary. . . .

The Court of Appeal’s decision essentially has tied the trial court’s hands, and an eventual judgment in favor of the Diocese and TEC is essentially inevitable. There are a number of procedural means by which that result could occur. Essentially what the congregations are left with is discretionary review by the CA Supreme Court, and if none is granted, a petition for a writ of certiorari in the US Supreme Court, which is also discretionary.

June 27, 2:38 pm | [comment link]
65. Connecticutian wrote:

#52/53, that is precisely the point the CT6 were trying to make in federal court, but the judge didn’t see any issues that warranted federal jurisdiction.  (Only diff being that CT statute granted the “hierarchical” recognition, not a judicial panel.) Unjust perhaps, but that’s what happened.

June 27, 2:59 pm | [comment link]
66. robroy wrote:

Maybe it’s time for a little nonviolent opposition. How about people protesting outside of Bruno services?

June 27, 10:01 pm | [comment link]
67. Tom Roberts wrote:

#68
I’d recommend instead Gamaliel’s prescription in Acts 5:34-9. Bruno also will pass away.

June 27, 10:34 pm | [comment link]
68. w.w. wrote:

Among points of interest:

This decision applies only to trial courts under the jurisdiction of this appellate division. Trial courts in other appellate divisions need pay no heed.

So, we can have the spectacle of departing parishes in Los Angeles unable to keep the property they bought, developed, and maintained, if this decision stands, while churches in other appellate jurisdictions may get to keep their property under state corporate law and the Dennis Canon isn’t worth the paper it’s printed on. This would be the case in the Fresno area, for example (though it’s unlikely any church in the Diocese of San Joaquin would be sued for its property, so Fresno would be a poor example—but it =is= home to the appeals court that gave St. Luke’s United Methodist the right to keep its property, a decision the United Methodist Church unsuccessfully sought review by the Calif. Supreme Court).

I don’t see how the state high court can sit idly by, while some counties automatically give deference to church hierarchies in legal matters concerning property disputes while other counties do not. This decision begs for review by the state’s highest court, IMO.

Completely irrelevant observation: At least two of these three judges apparently came from conservative Republican ranks. This =may= not bode well for the Virginia churches being sued by the Diocese of Va., if their case goes to the appeals level.  There may be a philosophical tilt among conservative jurists toward tradition and hierarchies. Generally, it is liberals who have championed neutral principles. Just nervous, off-the-wall speculation. smile

w.w.

June 27, 11:45 pm | [comment link]
69. theologian wrote:

Friends,
Recently a friend and I discussed whether ECUSA would be able to remain as part of the Anglican Communion.  I think a parting of the ways is probably inevitable, and that it will mean we (continuing members of ECUSA) tell our story by saying that “once we were a part of…”, much the same as Lutherans tell their story. 

I have a vision that will probably never come to pass, but it is this:  that both ECUSA and dissenters could agree to disagree, and to resolve individual disputes pastorally.  In fact, wouldn’t it be wonderful to have a liturgy to recognize the “divorce” and for each side to recognize that the other is acting in good conscience and good faith (however wrong-headed they may be)?  To ECUSA, I would say that it makes no sense to fight for each and every church building, for what good is the building if there is not a viable congregation to inhabit it?  But to dissenters I would ask that you acknowledge the broader pain that can come with loss of a building.  In my experience, a congregation does not just wake up one morning and decide to leave the denomination.  Very often, those who would not be “dissenters” have already left the congregation long before the formal breach arrives, so they are not there to be counted as part of the congregation.  (I speak from experience, having left a congregation that ultimately split from ECUSA over women’s ordination and the prayer book:  My parents, originally married in a civil ceremony, had their marriage blessed in the church on their 25th anniversary; my brother and I were confirmed in that church; my family worked many a weekend to help build the parish hall; my sister was married in that church, and her two children were baptized there.  It hurt terribly to leave that congregation and join another, but we couldn’t remain the way things were headed.) 

That said, may I ask a quick question of the gentleman from Connecticut?  Press reports last summer said that the “Connecticut 6” would be appealing the dismissal of their case from Federal Court; however, I haven’t been able to find any information about that.  Did they actually pursue an appeal, and if so do you know its status?

June 28, 3:21 am | [comment link]
70. Connecticutian wrote:

Theologian, the CT6 did appeal, but arguments have not started.  They have so far not filed the same complaints (minus civil rights questions) at the state level, where the fed judge said they properly belong.  There may be some news in the coming days.

June 28, 11:35 am | [comment link]
71. Jeff in VA wrote:

A little more in response to w.w. in #34 and my own post in #51:

Those who are interested and have access might be interested in 9 Witkin, California Procedure 4th, §§ 928-944, and esp. §§ 933, 937, and 938.

An excerpt from § 933:

Where Courts of Appeal have rendered conflicting decisions, what is the trial court to do? “As a practical matter, a superior court ordinarily will follow an appellate opinion emanating from its own district even though it is not bound to do so. Superior courts in other appellate districts may pick and choose between conflicting lines of authority. This dilemma will endure until the Supreme Court resolves the conflict, or the Legislature clears up the uncertainty by legislation.” (McCallum v. McCallum (1987) 190 C.A.3d 308, 315, 235 C.R. 396, footnote 4.)

(emphasis added)

June 28, 4:24 pm | [comment link]
72. w.w. wrote:

#73

Jeff. Thanks for posting that. It speaks to the issue I was wondering about in #70. The law concerning churches in Los Angeles County is totally different from the law concerning the same issues for churches in Fresno County. Heaven knows what it will be in San Diego and Sacramento et al.  How can the state supreme court sit by and NOT attempt to bring order out of this chaos? And if it does agree to hear an appeal in the Los Angeles cases, is it conceivable that it would in effect nullify what it let stand in the St. Luke’s Methodist case?

w.w.

June 29, 1:10 am | [comment link]
73. this_day wrote:

I’m uncertain what this appellate decision actually disposes of.  It reversed the lower court’s dismissal of the Diocese’s suit based on the parishes’ anti-SLAPP claims.  While the appellate court appeared to reach the merits of the underlying suit, I read that the issue re: the validity of the Denis Canon is still to be decided in the lower court.  First impression is that this ruling just has the effect of letting the diocese’s suit to proceed in the state Superior Court - in which case I believe the chances are great that the Denis Canon will be found to be an insufficient to create a trust without a concomitant clear intent on the part of the parishes.  Anyone have any thoughts about this - am I mistaken?

June 29, 1:29 am | [comment link]
74. Jeff in VA wrote:

w.w. (#74), sure thing.  (Also, check your e-mail.)

In the Witkin California practice guide I mentioned, there are lengthy discussions of whether a denial of cert is of the same precedential value as a grant and affirmation.  There are strong voices on both sides.  This assumes, of course, that the Supreme Court does NOT grant review (and that no petition for rehearing by the Court of Appeals is granted).

If certiorari is granted to the Supreme Court, there’s no question that if the Court rejected the Barker neutral principles line of case in favor of the Baker hierarchical deference line, all previous Court of Appeals decisions on the matter would be superseded.

As to whether the Supreme Court can sit by or not, I agree that doing so would only lead to more confusion, but that hasn’t really stopped them before.  This decision heightens the contradictions, so to speak, among the appellate circuits, but they were already there, and quite stark.  One need only read this opinion to see the differences - this court’s solution was to entirely reject the cases, including everything in the Barker - St. Luke’s line, as inconsistent with governing precedent, but it certainly recognized they couldn’t be reconciled.

this_day (#75), my understanding is that part of ruling on an anti-SLAPP motion (or on an appeal of a grant of one) is to essentially decide the merits (which, as you observe, the court did).  Under the Court of Appeals’ reading of California law (by which the Superior Court is now bound), there’s essentially no way the Superior Court could find for the parishes.  The remand for proceedings consistent is essentially a formality.

June 29, 7:55 am | [comment link]
75. Jeff in VA wrote:

One more thing, as a general comment.

As I understand it, the “Dennis Canon” is so called after +Walter Dennis, bishop and lawyer, who wrote it.

I understand the confusion that results from “canon” vs. “cannon” and consequently with “Dennis” vs. “Denis,” but just for the sake of historical accuracy, the stickler in me feels obliged to point it out.

June 29, 8:03 am | [comment link]
76. this_day wrote:

Jeff (#76)  Thanks for the explanation.  After I posted, I poked around a bit and did find that review of an anti-SLAPP dismissal is de novo .. I noted also that the decision commands that further proceedings be in conformity with the decision.  I suppose I allowed myself to become confused by media reports that the Dennis Canon issue was still outstanding (albeit, some wishful thinking was involved wink )

As an aside, I found the parishes’ anti-SLAPP claims interesting and creative.  Perhaps that type of argument can be honed and presented in a compelling way in future litigation in California - particularly if the various districts are not bound by appellate decisions in other districts.

[paying particular attention to the spelling of ‘Dennis’ and ‘canon’]

June 29, 8:07 am | [comment link]
77. Jeff in VA wrote:

this_day (#78), in regard to the anti-SLAPP motions to dismiss, here’s my take on it:

Although they present a novel approach in the context of church property disputes, they are unlikely to change the eventual outcome, as courts ruling on them are still required to weigh the plaintiff’s chance of success, and making such a determination requires the court to make a full examination of the substantive questions governed by the jurisdiction’s chosen standard from Watson or Jones just as it would in ruling on a motion for summary judgment or summary dismissal.  Accordingly, although local churches seeking the protection of an anti-SLAPP motion may be able to draw on another argument — abridgement of free-speech protections — that argument is insufficient on its own to ward off the claims made by the general church.  Of course, the anti-SLAPP motion is also only available to defendants alleging that the suit is being brought in response to an assertion of free speech rights, and thus will likely not be relevant in circumstances where the procedural posture of the parties is different (namely, where the suit is brought by the local congregation rather than the general church).

June 29, 8:19 am | [comment link]
78. Revamundo wrote:

So let’s say the dissenting churches win a legal victory, leave TEC and affiliate soley w/ Rawanda or something. What will you do when let’s say ++Akinola says “turn over your deeds and titles to AMiA.”

July 2, 12:14 am | [comment link]
79. Jeff in VA wrote:

Revamundo (#80), at least right now, the organization under ++Akinola’s jurisdiction (CANA) has this to say about property:

“Q19. Who will own a congregation’s property?
Each local congregation will hold title to its own property. In CANA there will be no “Dennis Canon” (a national canon purportedly passed in 1979 by which The Episcopal Church asserts an ownership interest in the property of all constituent member dioceses and congregations, subject to state law). Specific guidelines regarding the stewardship of local church property will be developed in such a way as to express biblical principles of justice and mutual accountability.”

If that policy should change, who knows what would happen.

(On a tangential note, ++Akinola doesn’t formally have anything to do with Rwanda or AMiA, as far as I know.  Your point is clear, though.)

July 5, 12:33 pm | [comment link]
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