Temple Lot Case
Encyclopedia
The Temple Lot Case also known as the Temple Lot Suit and formally known as "The Reorganized Church of Jesus Christ of Latter Day Saints, complainant, vs. the Church of Christ at Independence, Missouri" was a United States
legal case
in the 1890s which addressed legal ownership of the Temple Lot
, a significant parcel of land in the Latter Day Saint movement
. In the case, the Reorganized Church of Jesus Christ of Latter Day Saints (RLDS Church) claimed legal title of the land and asked the court to order the Church of Christ (Temple Lot)
to cease its occupation of the property. The RLDS Church won the case at trial, but the decision was reversed on appeal.
is a small parcel of land in Independence, Missouri
. In the early 1830s, the lot was designated by Joseph Smith, Jr. as the site for a proposed temple for a prophesied city of "Zion" or "New Jerusalem"
. In 1831, Latter Day Saint Bishop Edward Partridge
purchased the Temple Lot from Jones H. Flournoy and Clara Flournoy on behalf of Smith's Latter Day Saint church. Partridge held the property in trust for the church.
The proposed temple was never built on the site and the Latter Day Saints were ultimately driven out of Missouri
. After this, legal title to the property became a matter of dispute, with three separate theories of who inherited legal title to the property. The Church of Christ (Temple Lot)
(the "Hedrickites") ultimately found themselves in possession of the most prominent 2.5 acres (10,117.2 m²) portion of the 63.5 acres (256,975.6 m²) Bishop Partridge had purchased in 1831. On April 7, 1884, a Hedrickite conference authorized construction of a "house of worship" on the property, and on April 6, 1887, a building committee was formed and authorized by conference vote to immediately begin construction of the building. At their October 6, 1889 conference, the Hedrickites noted completion of the small church building on the northeast corner of the property, but no building was constructed on the exact site believed to have been designated for the temple—the central part of the sparsely-wooded field.
claiming equitable title to the Temple Lot, which was under the control by the Temple Lot church. After Joseph Smith's death
, the Latter Day Saint movement had splintered into a number of separate churches; Smith's son Joseph Smith III
was the president of the RLDS Church and claimed that the RLDS Church was the rightful successor to the original Latter Day Saint church. The Temple Lot church originally claimed the property on the basis of legal title, but later in the case also argued that it was entitled to the land as the rightful successor of the original church. The Utah-based LDS Church also participated in the case, providing funds and legal advice to the Hedrickites.
Perhaps to bolster their legal claim to the property, a Hedrickite conference announced Sunday, April 9, 1893 that construction of a long-awaited Latter-day Saint Temple would begin on the disputed property. Evidently on advice of their attorney, however, the strategy was abandoned, and soon forgotten in the confusion of rumors. The Chicago Tribune
reported:
After days of hearings which commenced February 7, 1894, the trial court ruled in March 1894 that the RLDS Church was the rightful successor to the original Latter Day Saint church, and that as such it was entitled to ownership of the property. The court also held that the doctrine of laches
did not apply since the Latter Day Saints had been driven out of Missouri and were therefore unable to assert their rights to the property.
. The appeals court disagreed with the trial court on the issue of laches, suggesting that the RLDS Church had unnecessarily delayed in asserting its rights over the property, and that in any case the legal title claims of the Hedrickites were probably superior to those of the RLDS Church. However, rather than reversing the decision of the trial court, the appeals court dismissed the case from the courts entirely, which meant that the controversy stood as though no case had ever been brought. In the result, the Hedrickites remained in possession of the Temple Lot by default.
The RLDS Church requested a second hearing before an en banc
panel of the Appeals Court, but the motion was dismissed. The RLDS Church then sought to appeal the decision to the United States Supreme Court, but that court denied certiorari
, which brought the case to a close.
United States
The United States of America is a federal constitutional republic comprising fifty states and a federal district...
legal case
Legal case
A legal case is a dispute between opposing parties resolved by a court, or by some equivalent legal process. A legal case may be either civil or criminal...
in the 1890s which addressed legal ownership of the Temple Lot
Temple Lot
The Temple Lot, located in Independence, Jackson County, Missouri, is the first site to be dedicated for the construction of a temple in the Latter Day Saint movement...
, a significant parcel of land in the Latter Day Saint movement
Latter Day Saint movement
The Latter Day Saint movement is a group of independent churches tracing their origin to a Christian primitivist movement founded by Joseph Smith, Jr. in the late 1820s. Collectively, these churches have over 14 million members...
. In the case, the Reorganized Church of Jesus Christ of Latter Day Saints (RLDS Church) claimed legal title of the land and asked the court to order the Church of Christ (Temple Lot)
Church of Christ (Temple Lot)
The Church of Christ is a denomination of the Latter Day Saint movement headquartered in Independence, Missouri on what is known as the Temple Lot. Members of the church have been known colloquially as "Hedrickites", after Granville Hedrick, who was ordained as the church's first leader in July 1863...
to cease its occupation of the property. The RLDS Church won the case at trial, but the decision was reversed on appeal.
Pre-trial ownership of Temple Lot
The Temple LotTemple Lot
The Temple Lot, located in Independence, Jackson County, Missouri, is the first site to be dedicated for the construction of a temple in the Latter Day Saint movement...
is a small parcel of land in Independence, Missouri
Independence, Missouri
Independence is the fourth largest city in the U.S. state of Missouri, and is contained within the counties of Jackson and Clay. It is part of the Kansas City Metropolitan Area...
. In the early 1830s, the lot was designated by Joseph Smith, Jr. as the site for a proposed temple for a prophesied city of "Zion" or "New Jerusalem"
Zion (Latter Day Saints)
Within the Latter Day Saint movement, Zion is often used to connote a utopian association of the righteous. This association would practice a form of communitarian economics called the United Order meant to ensure that all members maintained an acceptable quality of life, class distinctions were...
. In 1831, Latter Day Saint Bishop Edward Partridge
Edward Partridge
Edward Partridge was the grandson of Massachusetts Congressman Oliver Partridge, Esq., and a member of a family noted for commercial, social, political, and military leadership in Western Massachusetts. One of the first converts to the Latter Day Saint movement, he was baptized in or near Seneca...
purchased the Temple Lot from Jones H. Flournoy and Clara Flournoy on behalf of Smith's Latter Day Saint church. Partridge held the property in trust for the church.
The proposed temple was never built on the site and the Latter Day Saints were ultimately driven out of Missouri
Missouri
Missouri is a US state located in the Midwestern United States, bordered by Iowa, Illinois, Kentucky, Tennessee, Arkansas, Oklahoma, Kansas and Nebraska. With a 2010 population of 5,988,927, Missouri is the 18th most populous state in the nation and the fifth most populous in the Midwest. It...
. After this, legal title to the property became a matter of dispute, with three separate theories of who inherited legal title to the property. The Church of Christ (Temple Lot)
Church of Christ (Temple Lot)
The Church of Christ is a denomination of the Latter Day Saint movement headquartered in Independence, Missouri on what is known as the Temple Lot. Members of the church have been known colloquially as "Hedrickites", after Granville Hedrick, who was ordained as the church's first leader in July 1863...
(the "Hedrickites") ultimately found themselves in possession of the most prominent 2.5 acres (10,117.2 m²) portion of the 63.5 acres (256,975.6 m²) Bishop Partridge had purchased in 1831. On April 7, 1884, a Hedrickite conference authorized construction of a "house of worship" on the property, and on April 6, 1887, a building committee was formed and authorized by conference vote to immediately begin construction of the building. At their October 6, 1889 conference, the Hedrickites noted completion of the small church building on the northeast corner of the property, but no building was constructed on the exact site believed to have been designated for the temple—the central part of the sparsely-wooded field.
Pre-trial dispute
Observing lumber and other building materials rapidly accumulating on the site, on June 11, 1887, the RLDS Church served written notice to the Church of Christ (Temple Lot) to "cease and desist" performing any construction on the disputed site. However, construction continued and media reports of the day indicate that a habitable structure was in place as early as that summer of 1887. On September 10, 1888, visiting elders from the Utah-based Church of Jesus Christ of Latter-day Saints (LDS Church) were welcomed and invited to lecture in the building, which apparently was completed by that time.Trial
On August 6, 1891 the RLDS Church filed suit in the United States District Court for the Western District of MissouriUnited States District Court for the Western District of Missouri
The United States District Court for the Western District of Missouri is the federal judicial district encompassing 66 counties in the western half of the State of Missouri...
claiming equitable title to the Temple Lot, which was under the control by the Temple Lot church. After Joseph Smith's death
Death of Joseph Smith, Jr.
The death of Joseph Smith, Jr. on June 27, 1844 marked a turning point for the Latter Day Saint movement, of which Smith was the founder and leader. When he was attacked and killed by a mob, Smith was the mayor of Nauvoo, Illinois, and running for President of the United States...
, the Latter Day Saint movement had splintered into a number of separate churches; Smith's son Joseph Smith III
Joseph Smith III
Joseph Smith III was the eldest surviving son of Joseph Smith, Jr., founder of the Latter Day Saint movement, and Emma Hale Smith...
was the president of the RLDS Church and claimed that the RLDS Church was the rightful successor to the original Latter Day Saint church. The Temple Lot church originally claimed the property on the basis of legal title, but later in the case also argued that it was entitled to the land as the rightful successor of the original church. The Utah-based LDS Church also participated in the case, providing funds and legal advice to the Hedrickites.
Perhaps to bolster their legal claim to the property, a Hedrickite conference announced Sunday, April 9, 1893 that construction of a long-awaited Latter-day Saint Temple would begin on the disputed property. Evidently on advice of their attorney, however, the strategy was abandoned, and soon forgotten in the confusion of rumors. The Chicago Tribune
Chicago Tribune
The Chicago Tribune is a major daily newspaper based in Chicago, Illinois, and the flagship publication of the Tribune Company. Formerly self-styled as the "World's Greatest Newspaper" , it remains the most read daily newspaper of the Chicago metropolitan area and the Great Lakes region and is...
reported:
After days of hearings which commenced February 7, 1894, the trial court ruled in March 1894 that the RLDS Church was the rightful successor to the original Latter Day Saint church, and that as such it was entitled to ownership of the property. The court also held that the doctrine of laches
Laches (equity)
Laches is an "unreasonable delay pursuing a right or claim...in a way that prejudices the [opposing] party" When asserted in litigation, it is an equitable defense, or doctrine...
did not apply since the Latter Day Saints had been driven out of Missouri and were therefore unable to assert their rights to the property.
Appeal
The Church of Christ (Temple Lot) appealed the trial court's decision to the United States Court of Appeals for the Eighth CircuitUnited States Court of Appeals for the Eighth Circuit
The United States Court of Appeals for the Eighth Circuit is a federal court with appellate jurisdiction over the district courts in the following districts:* Eastern District of Arkansas* Western District of Arkansas...
. The appeals court disagreed with the trial court on the issue of laches, suggesting that the RLDS Church had unnecessarily delayed in asserting its rights over the property, and that in any case the legal title claims of the Hedrickites were probably superior to those of the RLDS Church. However, rather than reversing the decision of the trial court, the appeals court dismissed the case from the courts entirely, which meant that the controversy stood as though no case had ever been brought. In the result, the Hedrickites remained in possession of the Temple Lot by default.
The RLDS Church requested a second hearing before an en banc
En banc
En banc, in banc, in banco or in bank is a French term used to refer to the hearing of a legal case where all judges of a court will hear the case , rather than a panel of them. It is often used for unusually complex cases or cases considered to be of greater importance...
panel of the Appeals Court, but the motion was dismissed. The RLDS Church then sought to appeal the decision to the United States Supreme Court, but that court denied certiorari
Certiorari
Certiorari is a type of writ seeking judicial review, recognized in U.S., Roman, English, Philippine, and other law. Certiorari is the present passive infinitive of the Latin certiorare...
, which brought the case to a close.
Reactions
Leaders of the RLDS Church widely interpreted the result of the case as a technical vindication of the church's claim as being the rightful successor to the original Latter Day Saint church. Joseph Smith III and his successor, Israel A. Smith, both argued that the RLDS Church had been denied title to the Temple Lot merely because of the doctrine of laches, and that the courts had confirmed that otherwise their title was superior. The Temple Lot church has consistently maintained that the case stands as the final validation of their right to possess the Temple Lot. The LDS Church, although it assisted the Hedrickites in the case, has not taken an official position on the outcome of the case.External links
- "Decision of John F. Philips, judge, in Temple Lot case : the Reorganized Church of Jesus Christ of Latter Day Saints versus the Church of Christ, et al (1894)"
- Full text of Complainant's abstract of pleading and evidence in The Reorganized Church of Jesus Christ of Latter Day Saints, complainant, vs. the Church of Christ at Independence, Missouri Published in 1893 by the RLDS Herald Publishing House, 507 pages of information about the "Temple Lot Suit"
- An Introduction to the Temple Lot Case -- An essayEssayAn essay is a piece of writing which is often written from an author's personal point of view. Essays can consist of a number of elements, including: literary criticism, political manifestos, learned arguments, observations of daily life, recollections, and reflections of the author. The definition...
by R. Jean Addams at "Signature BooksSignature BooksSignature Books is a press specializing in subjects related to Utah, Mormonism, and Western Americana. The company was founded in 1980 by George D...
Library" page, September, 2010.