In Chestnut v. United Methodist Church, (NY App. Div., July 10, 2024), a New York state appellate court held that the "United Methodist Church" is not a jural entity that can be sued under New York's Child Victims Act. Plaintiff, who alleged that she was sexually abused as a young child over a 4-year period by a youth group leader who was also the son of a clergyman, named 6 defendants. She alleged that United Methodist Church was in a principal-agent relationship with the Woodbury, New York church that employed the abuser. The court said in part:
Here, the issue of whether United Methodist Church is a jural entity capable of being sued does not concern a religious controversy, and, therefore, does not require the interpretation or application of ecclesiastical doctrine. Instead, the issue of whether United Methodist Church may be considered an unincorporated association rests entirely on neutral principles of law....
... [W]e conclude that the defendants established that United Methodist Church ... is a religious denomination ... and not a jural entity amenable to suit as an unincorporated association. It is undisputed that United Methodist Church does not have a principal place of business, does not have its own offices or employees, and does not and cannot hold title to property, and there is no proof in the record that United Methodist Church has incorporated or held itself out as a jural entity in any other jurisdiction....
... United Methodist Church governs itself through the efforts of United Methodists from all over the world who, at various levels, propose and adopt policies and procedures in the Discipline to be followed by, among others, local churches, annual conferences, and the various corporate entities at the general church level, such as GCFA. Given this unique structure, the hierarchical nature of United Methodist Church's "connectional" structure does not, in and of itself, suggest that United Methodist Church is an unincorporated association or anything other than a religious denomination.
