Church In Bankruptcy Need Not Disclose Membership List

In re Deliverance Christian Church, 2011 Bankr. LEXIS 5219 (ND OH, Dec. 1, 2011), involves the issue of how much information a church in bankruptcy must furnish to a bank that is a secured creditor of the church.  While the church agreed that the bank is entitled to financial information, at issue in the case is whether it is entitled to the church's membership list, or instead whether the church may furnish information in which contributors are identified only by numbers. The court held that membership lists are subject to heightened protection because of the chilling effect on freedom of association, membership and future giving that may result from their release. Since the bank had not shown a compelling need for actual names of members or contributors, the court ordered production in discovery of all documents relating to tithes or donations, including pledge commitment records, but the church was authorized to provide a sanitized version to protect the personal information of contributors.