Universal Life Church Legal Cases

Universal Life Church v. Landes (Virginia)

On May 22, 2025 the Universal Life Church filed a lawsuit against officials for Augusta County, VA and the City of Staunton, VA over the discrimination that our ministers had faced in those areas when they attempted to solemnize marriages. This is despite the fact that ministers of all other religions are permitted to solemnize marriages in the state. The ULC is hopeful that a victory in this lawsuit will effectively restore and protect the rights of its ministers to practice their faith freely across the entire Commonwealth of Virginia. This case is ongoing.

Universal Life Church v. Nabors (Tennessee)

After the Tennessee state legislature passed a law explicitly barring ministers who were ordained online from solemnizing legal marriages, the Universal Life Church immediately filed suit and were successful in obtaining a restraining order blocking the law from taking effect.

In August of 2023, the ULC began trial against Tennessee state officials responsible for upholding the anti-ULC law. During the course of that trial, the Tennessee state officials agreed to hand ULC the victory by settling with the church and declaring that in their jurisdictions no ULC ministers would be prosecuted under the law because enforcement of that law could be a constitutional violation.

Universal Life Church v. McGeever (Pennsylvania)

The Universal Life Church filed a Federal lawsuit against Allegheny County, Pennsylvania after learning that the county had repeatedly denied its ministers the right to solemnize marriage by refusing to recognize the validity of their ordinations.

On June 6, 2022 the court issued an order accepted the settlement reached between ULC and Allegheny County, which further ordered that any denial or discouragement of the rights of ULC ministers to solemnize legal marriages was unconstitutional.

Universal Life Church v. Goya (Nevada)

The Universal Life Church filed suit against Clark County, NV and County Clerk Lynn Goya when new rules and requirements established by the Clark County Clerk’s Office effectively made it impossible for ULCM Ministers to solemnize marriages in the area. The case was ultimately settled in ULC’s favor and ULC ministers can operate fully in Clark County provided they abide by proper procedure.

Universal Life Church v. Bobrin (Pennsylvania)

The Universal Life Church filed a Federal lawsuit against officials in Bucks County, Pennsylvania after learning that one of the Church's ministers was told he could not practice his religion and solemnize a legal wedding ceremony because of the source of his ordination.

The Universal Church, Inc. v. Universal Life Church

The Universal Church, Inc. alleged that the Universal Life Church had infringed on their “Universal Church” trademark and cyber-squatted on a domain containing that name in the URL. The ULC responded by challenging the validity of the “Universal Church” mark on the grounds that it was overly generic and a common term used throughout history to refer to different religious organizations, most notably the Catholic Church. A New York federal court granted summary judgment to the ULC in that matter, and Universal Church, Inc. chose to file an appeal.

In November of 2018, the US Court of Appeals for the Second Circuit in New York affirmed the ruling of the lower court that the “Universal Church” trademark was improperly granted and that the Universal Life Church never behaved improperly.

The Supreme Court declined to hear an appeal on Universal Church v. Toellner after Universal Church filed a writ of certiori. This denial solidifies the previous ruling of the Appeals Court, affirming that “Universal Church” is a historic term and not a reference to any one specific organization.

Universal Life Church v. Michael J. Cauley

This case regarded the breach of a mediated settlement agreement which resulted from defamation disputes between the Universal Life Church and Michael J. Cauley / "ULC World Headquarters". The Universal Life Church argued that Michael J. Cauley breached that agreement by continuing to make defamatory statements about the Church. Cauley claimed he was unable to remove the offending posts as he no longer had access to the online accounts he had used to post them, which the Church was able to demonstrate was calse in district court by showing a history of edits to the posts after the date on which he claimed he lost access. The 11th Circuit affirmed the ULC's victory via summary judgment after Cauley appealed.

Universal Life Church v. Utah

In 2001, Utah’s legislature passed a bill attempting to stop people who were ordained online or by mail from officiating marriages. This case was filed by the Universal Life Church in response, as the bill was clearly a targeted attack on the ULC, and the Church believed it to be fundamentally unconstitutional.

After reaching US District Court, a precedent-setting memorandum was issued affirming the right of Universal Life Church ministers to perform marriages.

Universal Life Church v. United States

Here, ULC Modesto challenged the IRS’s earlier revocation of its federal §501(c)(3) tax-exempt status, arguing that the revocation was invalid because it occurred while the Church was in bankruptcy and therefore violated the bankruptcy automatic stay. The Ninth Circuit rejected that argument, holding that the IRS’s revocation fell within the Bankruptcy Code’s “police or regulatory power” exception, meaning the government could enforce federal tax laws despite the stay. The court also agreed with the lower court that the Church had not been operated exclusively for tax-exempt purposes during the relevant years, so the revocation of its exemption remained valid. Our organization (the Universal Life Church Monastery Storehouse) maintains no affiliation with ULC Modesto, in large part because of the troubling financial history of that entity.

Universal Life Church v. The IRS

In this groundbreaking case, the Universal Life Church sued for a refund of federal income taxes paid for its fiscal year ending April 30, 1969, after the IRS had denied the Church tax-exempt treatment on the theory that some of its activities—especially ordaining ministers, issuing church charters, and granting honorary doctorates—were outside the scope of a qualifying religious organization. The district court ruled for the Church, holding that courts could not deny exemption simply because a religion’s beliefs or practices seemed unusual.

Lynch v. Universal Life Church

In 1985, a federal jury temporarily awarded a woman named Sandra Lynch $160,000 after finding that the ULC Modesto "fraudulently misrepresented" that its ministers could perform valid marriages in North Carolina. The Fourth Circuit reversed judgment, holding that Lynch’s fraud claim was barred by the three-year statute of limitations because she reasonably should have known by 1978 that her marriage might be invalid. The court also ruled that Lynch failed to prove fraud because the ULC Modesto never represented that its ministers were legally authorized under North Carolina law, and instead explicitly instructed ministers to check with local officials. Because the ULC Modesto neither made a false legal representation nor intended anyone to rely on one, judgment was entered in favor of the Universal Life Church Modesto.

O'Neill Memorandum (Pennsylvania)

The court was asked to decide whether a marriage performed by a minister ordained by the Universal Life Church was valid under Pennsylvania law. The court held that the ULC is a regularly established church and that its ordained ministers qualify as “ministers” authorized to solemnize marriages under the Pennsylvania Marriage Act. It rejected narrower interpretations from other states and ruled that Pennsylvania law is intentionally broad to accommodate diverse religious practices. As a result, the court declared Jason and Jennifer O’Neill’s marriage legally valid and entered a decree confirming their marital status.

Ranieri v. Ranieri (New York)

Rae B. Ranieri sought a divorce settlement from her husband, Rocco J. Ranieri, after a ceremony performed by a ULC Modesto minister, and she opposed Rocco’s effort to nullify the marriage. The court held that a New York marriage solemnized by a ULC Modesto “minister” is void because such an officiant does not qualify as a “clergyman or minister” authorized under Domestic Relations Law § 11 and the Religious Corporations Law. Because the marriage was void, the court also ruled that the two antenuptial agreements, including the promise to pay $90,000, were unenforceable. The Appellate Division reversed the lower court’s temporary support orders and entered judgment that the financial elements of the prenuptial agreements could not be enforced, but remanded some other issues in the case.

Blackwell v. Magee (Mississippi)

The Mississippi Supreme Court considered whether a marriage performed by a Universal Life Church (ULC) minister was legally valid for purposes of a widow’s inheritance rights. The family of a deceased former wife of Colbert Blackwell attempted to claim rights to his estate, althouth Blackwell was married to another woman at the time of his death. His marriage to his current wife had been performed by a ULC minister. After the chancery court ruled the marriage invalid and denied Nadine Blackwell her spousal share, the Supreme Court reversed that decision, holding that a ULC minister qualifies as a “spiritual leader of a religious body” under Mississippi law. The court emphasized that Mississippi’s marriage statute permits ULC ministers to solemnize marriages. As a result, Nadine Blackwell was legally recognized as Colbert Blackwell’s widow and entitled to pursue her statutory rights in his estate.

ULC Modesto California Tax Ruling

A man named Robert V. Fike appealed a decision by the Franchise Tax Board of California which required him to pay taxes on large donations he had made to the Universal Life Church of Modesto, California. Fike’s donations were allegedly channeled through the ULC Modesto to pay for his personal living expenses. The court discovered that ULC Modesto had had its tax exempt status retroactively reversed in a earlier ruling, and Fike ultimately was required to pay the State.

Fulton v. Vickery (North Carolina)

Lynn Stone Fulton sued her former husband, the officiant, and the ULC Modesto, alleging that she had been negligently or fraudulently induced into a void marriage because the ceremony had been performed by a ULC Modesto minister. The North Carolina Court of Appeals affirmed summary judgment for the defendants, holding that a curative statute validated the marriage, that the evidence did not support fraud or negligence, and that the claims were time-barred in any event.

Rubino v. New York City

A group of ULC Modesto ministers challenged New York City’s refusal to register them to perform marriages, claiming it violated their First Amendment rights. The court held that while religious belief is protected, there is no constitutional right to perform marriages, which are heavily regulated by the state because of their legal and social consequences. Relying on prior court rulings, including Ravenal v. Ravenal, the court found that ULC Modesto ministers had been judicially determined to lack authority to solemnize marriages. Because of the state’s strong interest in preventing invalid marriages, the city clerk’s refusal to register ULC Modesto ministers was neither arbitrary nor unconstitutional. Since this time, there have been several developments and the New York City clerk's office now regularly registers Universal Life Church ministers seeking to solemnize marriages.

North Carolina v. Lynch

A man named James Lynch was convicted of bigamy after it was discovered that he had already been married to another woman after a ceremony solemnized by her father (an ordained minister of ULC Modesto), after he became married again to a second woman in a ceremony perfomred by a Moravian minister. This was before ULC ministers were regulary recognized by officials in North Carolina. As a result, his first marriage was declared void and his bigamy conviction was reversed. North Carolina would later pass a law validating the marriages performed by ULC ministers.

Cramer v. Virginia

In 1974, several Universal Life Church ministers appealed after a Richmond circuit court rescinded their authority to solemnize marriages in Virginia under Code § 20-23. The Virginia Supreme Court held the statute is not limited to full-time clergy and does not impose a religious test, but it does allow the Commonwealth to require that those who perform marriages be "responsibly selected, certified, and accountable" because of the state’s strong interest in valid marriage records. Applying that standard, the court concluded that individuals “ordained” essentially on request through an organization with enormous numbers of ministers and minimal selection or oversight were not “ministers” within the meaning of the statute for marriage-solemnization authority. The rescission order was therefore affirmed. As of 2026, the Universal Life Church is again engaged in an ongoing lawsuit against Virginia to clarify and affirm the status of its ordained ministers.

Ravenal v. Ravenal (New York)

In 1972, the New York Supreme Court annulled a marriage that had been performed by a ULC minister. The court held that New York law requires a marriage to be solemnized by a clergyman who has real authority from an "actual church" or religious congregation, not merely a paper certificate. Because, court argued at the time, the officiant was not connected to what it considered a functioning church, congregation, or religious body that authorized him to perform marriages, he did not qualify as a lawful minister. As a result, the marriage was declared invalid and annulled. Since this time, the legal situation in New York has changed significantly and ULC ministers regularly solemnize weddings there.

2002 Attorney General Opinion - Texas

In 2002, the Texas Attorney General concluded that the Texas State Board of Examiners of Psychologists may consider Internet or mail-order ordination as one factor when determining whether an individual qualifies as a “recognized member of the clergy” exempt from psychologist licensing requirements. However, the Board may not automatically deny clergy status based solely on the method of ordination, as doing so could raise constitutional concerns under the First Amendment and equal protection principles.

1997 Attorney General Opinion - Tennessee

In 1997, the Tennessee Attorney General concluded that marriages performed by ministers ordained through the Universal Life Church are presumed legally valid under Tennessee law. He further opined that a court may declare such a marriage void only if the challenging party carries the burden of presenting strong and convincing evidence that the officiant lacked legal authority under Tennessee law.

1978 Attorney General Opinion - Kentucky

The Kentucky Attorney General concluded that ministers ordained by the Universal Life Church may perform valid, legal marriages in Kentucky if they meet the statutory requirements applicable to ministers of a religious society. Kentucky law broadly defines a “religious society” as any group organized and maintained for public worship, leaving the determination of who qualifies as a minister to the recognition practices of the individual denomination rather than imposing formal ordination requirements.

1973 Attorney General Opinion - South Carolina

Only ministers of the Gospel or accepted Jewish rabbis and officers authorized to administer oaths in this State are authorized to administer a marriage ceremony in this State. However, as long as a minister is able to meet the statutory requirements of the state, they are qualified to solemnize marriages.

1971 Attorney General Opinion - South Carolina

In 1971, the South Carolina Attorney General concluded that, unless the Universal Life Church is formally determined not to be a bona fide religious organization, its ordained ministers should be recognized as having authority to perform marriage ceremonies — the same right afforded to ministers of any other religion.

Lineker v. Alaska

Maria and Michael Lineker claimed that their marijuana-growing operation was protected as a religious practice under the Alaska Constitution and cited their Universal Life Church membership and related cannabis-ministry materials. After remand for an evidentiary hearing, the trial court found that the asserted beliefs were not sincere but instead were developed as a litigation strategy after arrest, and the Court of Appeals upheld that determination.

Dolenz v. Dallas Central Appraisal Dist. (Texas)

In this property tax dispute, Bernard Dolenz challenged the denial of a Texas tax exemption after he conveyed Dallas property to the “Universal Life Church of Texas Trust” while retaining a life estate and argued that the property was exempt as religious property. The Texas Court of Appeals affirmed dismissal for lack of jurisdiction/standing, concluding that Dolenz was not the proper party to pursue the exemption claim in his own name. The connection to the Universal Life Church is only that the trust claiming ownership used the ULC name; the case did not involve the Universal Life Church entity which operates this website.

Branch v. Chamisa Dev. Corp. (New Mexico)

A real estate broker sued a mall developer claiming he was defrauded into accepting a settlement that undervalued his 10% interest in a Santa Fe shopping center. He argued Chamisa hid higher purchase offers and misstated the property’s value. Because the broker had retained the $1 million payment he had received from Chamisa, the court held that he could not rescind the settlement and was bound by its broad release of all claims. The court also ruled the parties were in an arm’s-length business relationship with no fiduciary duty, so his fraud and contract claims were barred. An older New Mexico case involving the ULC Modesto's tax status was cited as part of the proceedings.

Santa Fe Estates, Inc. v. Concerned Residents of Santa Fe N., Inc. (New Mexico)

Residents of New Mexico challenged a proposed office development as violating a 1996 settlement/master plan that included design and use limits for a commercial area. The court held Estates couldn’t block the contract lawsuit with res judicata because it effectively acquiesced in claim-splitting by not timely objecting while the parallel administrative appeals were pending. It also upheld the trial court’s finding that the settlement documents were ambiguous and created enforceable restrictions requiring Estates to record covenants before any transfer of the commercial property. The court affirmed and rejected Residents’ attempt to expand enforcement to every guideline in the vision statement. An older New Mexico case involving the ULC Modesto's tax status was cited as part of the proceedings.

People v. Rubin (California)

Craig Rubin was a man convicted of the unlawful sale of marijuana prior to its legalization in California. He had been operating a business called "Temple 420", which he claimed was a Church in which members could purchase marijuana. An undercover officer, who was not a member of "Temple 420" was successfully able to purchase marijuana from an employee at the venue. As part of his defense, Mr. Rubin testified that he was a Universal Life Church minister and argued that his personal religious beliefs protected his activities. The trial court and the appeals court ultimately ruled that a person's religious beliefs do not generally exempt them from drug laws, and that "Temple 420" appeared to be engaging in overtly commercial marijuana activity, not protected sacramental use.

Rudy v. Intermountain Agency, Inc. (New Mexico)

This New Mexico case centered around res judicata issues. The Universal Life Church was not a party to the case, or otherwise involved to any extent beyond that an older New Mexico case involving the ULC Modesto's tax status was cited as part of the proceedings.

Duncan v. Duncan (North Carolina)

On 15 October 1989, plaintiff Barbara Duncan and defendant John Duncan (collectively, “the couple” or “the Duncans”) participated in a Native American marriage ceremony performed by Hawk Littlejohn, a Cherokee Medicine Man, who possessed a certificate stating that he was ordained by the ULC Modesto. Following the ceremony, plaintiff changed her last name, the couple signed a marriage certificate and filed it with the Macon County Register of Deeds, and the Duncans held themselves out in the community as a married couple. The Duncans had two children together: a son who was born in 1986, and a daughter who was born in 1993. In 2001, an estate planning attorney questioned the validity of the couple’s 1989 marriage ceremony. The attorney advised the Duncans to conduct a new marriage ceremony, and they took his advice. On 14 October 2001, the couple held another marriage ceremony at The First Presbyterian Church in Franklin, North Carolina.

Computer One, Inc. v. Grisham & Lawless, P.A. (New Mexico)

Computer One inc. sued its former lawyers for malpractice after the lawyers took out a lien against the settlement proceeds won in the underlying case. The lower courts ruled the malpractice claim was barred because it should have been raised as a compulsory counterclaim (and was also precluded by res judicata) when the client objected to the lien. The New Mexico Supreme Court reversed, holding that a charging lien is a limited, equitable fee-collection mechanism and does not automatically make the client and lawyer “opposing parties” for compulsory-counterclaim purposes, so the malpractice claim was not barred. The case was remanded for the malpractice claim to proceed, while noting the client still could not relitigate issues actually decided earlier (like the lawyers’ authority to settle).

Tennessee v. Sherman

This case began in 2001 when a person named Ariel Ben Sherman, who claimed to be a ULC minister, rented a house in Tennessee and began conducting services there. Later, they moved eight more individuals into the home, including a teenaged girl. Unfortunately, that girl would pass away the following year from bone cancer. A trial court was asked to determine whether Sherman was guilty of child neglect, as at the time he was effectively behaving-like and holding himself out as her father, and he allegedly did not pursue adequate medical treatment for the girl. The trial court dismissed that charge before trial, but the Tennessee Supreme Court ultimately re-instated the child neglect charge and remanded the case for further hearing. The only connection between the ULC and this case was that Mr. Sherman had at one time claimed to be a ULC minister.

District of Columbia. v. Craig (Washington D.C.)

This District of Columbia case involved challenges to property-tax assessments and the availability of judicial review despite tax-administration barriers. The D.C. Court of Appeals addressed whether the taxpayers could proceed in court and how the assessments and related procedures should be evaluated under District law. The Universal Life Church was not a party; it appears only indirectly because the opinion cites a case involving the Church as part of broader legal analysis.

Prell v. Silverstein (Hawai'i)

This is a complex case regarding marital property and how it ought to be distributed post-divorce given the existence of a pre-nuptial agreement. There are a number of legal issues at play within the case, mostly regarding that pre-nuptial agreement. The name of the Universal Life Church is only cited in the case because the couple's 1980 marriage was apparently performed by a ULC minister, but the ULC is neither a party not otherwise materially involved. Ultimately, an appellate court held the family court erred in finding the premarital agreement unenforceable, explaining that marriage can supply consideration and the record did not support unconscionability or lack of voluntary assent for the property-division terms. Because the agreement was valid, the court also held the family court misclassified the husband’s one-half interest in the Kalapana property (purchased with gifted funds) and vacated portions of the property-division rulings. However, it affirmed the order requiring sale of the Kalapana property interest to satisfy debts and child-support obligations, and remanded for further proceedings.

Rosette, Inc. v. U.S. Dep't of the Interior (New Mexico)

This was a New Mexico water-rights / geothermal-resources case: Rosette tried in state court to establish rights to hot groundwater beneath its land, but the New Mexico Court of Appeals held that the dispute was really an attempt to relitigate ownership of geothermal resources already resolved against Rosette in prior federal litigation, so the claims were barred and the state court lacked jurisdiction over the federal government on that theory. The connection to the Universal Life Church is purely incidental and doctrinal: the opinion cites Universal Life Church v. Coxon only as an earlier New Mexico case that had overruled Three Rivers Land Co. v. Maddoux on other grounds, while discussing claim preclusion; ULC itself was not a party and the case has nothing to do with ordination, marriage, or church rights.

Salazar v. Torres (New Mexico)

Phillip Salazar was severely burned after his employer told him to pour gasoline into a truck carburetor and, while he was still doing so, directed another person to start the ignition. After receiving workers’ compensation benefits, Salazar sued under Delgado, alleging intentional or willful employer conduct, and the New Mexico Court of Appeals held that receipt of workers’ compensation benefits did not bar that tort claim. The connection to the Universal Life Church is only indirect: the opinion cites Universal Life Church v. Coxon while discussing New Mexico election-of-remedies doctrine.

Moffat v. Branch (New Mexico)

This is medical-malpractice case in which attorney Stephen Moffat had originally represented Elizabeth Vincoy and her son, was later replaced by attorneys James Branch and Joseph Branney, and then tried to recover part of the eventual $4.8 million Federal Tort Claims Act settlement by asserting an attorney’s charging lien and later contract-based theories like unjust enrichment and quantum meruit; the New Mexico Court of Appeals held those later claims were barred by claim preclusion because they arose from the same core transaction—the prior representation, settlement, and fee dispute—and should have been pursued in the earlier federal proceeding. The connection to the Universal Life Church is only indirect: Moffat cites Three Rivers Land Co. v. Maddoux as having been “overruled on other grounds by Universal Life Church v. Coxon,” so the ULC case appears merely as background precedent on New Mexico preclusion procedure, not because the Church or its ministers had any factual role in Moffat itself.

Spratt v. Rhode Island Dep't of Corrections

This is a case about prisoners’ religious rights under the Religious Land Use and Institutionalized Persons Act (RLUIPA). The plaintiff, an inmate, had been allowed for years to preach at prison religious services but was later prohibited from doing so by prison officials, who claimed security concerns. The First Circuit held that the prison had not demonstrated that the ban was the least restrictive means of serving a compelling security interest and therefore vacated summary judgment for the Department of Corrections. The Universal Life Church appears only in passing in the factual background: Spratt had been ordained as a minister through the Universal Life Church, which he cited as part of his religious identity, but the case itself concerns prisoners’ religious-exercise rights under RLUIPA rather than any legal issue about ULC ordination.

Pickard v. Pickard (North Carolina)

In this case, Carl Pickard sought to annul his 11-year marriage to Jane Pickard after the couple separated, arguing that their 1991 ceremony was invalid because it had been performed by Hawk Littlejohn, a Cherokee medicine man who also held a Universal Life Church ordination certificate, and thus allegedly was not legally authorized to solemnize marriages under North Carolina law; the North Carolina Court of Appeals rejected the annulment effort, holding in substance that Carl could not undo the marriage after years of holding himself out as married, including in a sworn adult-adoption proceeding. The case connects to the Universal Life Church because Littlejohn’s ULC ordination was central to the challenge to the validity of the ceremony, making the case one of the North Carolina decisions often discussed in disputes over whether marriages performed by ULC ministers are valid under state law.

Ross v. Arkansas

In this case, Scott Randall Ross was convicted of first-degree murder after, according to the evidence, his car was rear-ended in Hot Springs, Arkansas, he became enraged, and he shot the other driver, Inocencio Cruz; on appeal he argued, among other things, that statements he made afterward to his friend Steve Long should have been excluded under the clergy-communication privilege, but the Arkansas Court of Appeals rejected that argument because Long was acting as Ross’s friend in a bar setting, not as a spiritual adviser, when Ross confessed that he had shot the man. The case connects to the Universal Life Church because Long’s claimed ministerial status came from an honorary degree he had obtained online from the Universal Life Church, which Ross relied on in trying to invoke the religious privilege; the ULC itself was not a party, and the case did not decide any broader issue about ULC ordinations beyond treating that fact as part of the failed privilege claim.

San Francisco v. PG&E (California)

In City & County of San Francisco v. PG&E Corp., California’s Attorney General and the City of San Francisco sued PG&E’s parent company in state court, alleging it had improperly transferred billions of dollars derived from utility ratepayers while the utility subsidiary was in Chapter 11 bankruptcy; they sought injunctive relief, civil penalties, and restitution under California’s unfair-competition law, and the Ninth Circuit held that these were governmental “police or regulatory power” actions that could not be removed to bankruptcy court, including the restitution claims because they primarily served public-welfare and law-enforcement purposes rather than the government’s own pecuniary interests. The connection to the Universal Life Church is purely precedential: the Ninth Circuit relied on Universal Life Church v. United States (In re Universal Life Church, Inc.), 128 F.3d 1294 (9th Cir. 1997), for the “pecuniary purpose” and “public policy” tests used to decide whether a government action falls within the bankruptcy police-power exception; the Church itself had no factual role in the PG&E dispute.

Railroad Mgmt. Co. v. CFS La. Midstream Co. (Southern U.S.)

This is a case over a commercial dispute: Strong Capital and Railroad Management claimed Union Pacific had assigned them the right to collect annual pipeline-license payments from CFS for a pipeline crossing railroad land, but when CFS did not pay, the plaintiffs could not produce admissible proof of the assignment, and the Fifth Circuit affirmed summary judgment against them, also rejecting the argument that CFS’s silence created an implied contract. The case connects to the Universal Life Church only indirectly, because the court discussed and distinguished Ruberto v. Commissioner, a Second Circuit case involving taxpayers’ claimed donations to the Universal Life Church, when explaining why the plaintiffs here were not entitled to another chance to submit better evidence; the ULC itself had no role in the underlying pipeline dispute.

Lockyer v. Mirant Corp. (California)

In Lockyer v. Mirant Corp., the California Attorney General and other state officials sued the energy company Mirant in California state court, alleging that Mirant had manipulated electricity markets during California’s energy crisis and seeking injunctive relief and restitution under state unfair-competition laws; Mirant, which was in Chapter 11 bankruptcy, argued that the case should be halted because it interfered with the bankruptcy proceeding, but the Ninth Circuit held that the suit fell within the bankruptcy code’s “police and regulatory power” exception and therefore could proceed because it was primarily an effort to protect the public rather than to advance the state’s own pecuniary interests. The connection to the Universal Life Church is purely precedential: in analyzing whether the state’s action served a public regulatory purpose or a pecuniary one, the court relied on the Ninth Circuit’s earlier decision in Universal Life Church, Inc. v. United States, which articulated the “pecuniary purpose” and “public policy” tests used to determine whether government actions fall within that bankruptcy exception; the Church itself had no role in the Mirant litigation.

Cagan v. Village of Angel Fire (New Mexico)

In this case, Carol Platt Cagan, J.D. Wolf, and Lobo Land sued the Village of Angel Fire and village officials after alleging the Village had made politically motivated decisions against their businesses, including claims under § 1983, breach of contract, and related tort theories tied to an agreement with the Village; after their first case was dismissed with prejudice for failure to prosecute, they filed a second case raising overlapping claims, and the New Mexico Court of Appeals held that most of those repeat claims were barred by res judicata, though one claim was sufficiently distinct to survive and be remanded. Its connection to the Universal Life Church is only indirect: in stating New Mexico’s res judicata test, the court cited Three Rivers Land Co. v. Maddoux and noted that it had been “rev’d on other grounds by Universal Life Church v. Coxon,” so the ULC appears only as background precedent on claim-preclusion procedure, not as a party or factual participant in the dispute.

Cordova v. Larsen (New Mexico)

In this case, the administrator of Antonio Cordova’s estate tried to reopen a decades-old wrongful death case arising from the 1972 police killings of Antonio Cordova and Rito Canales, arguing through an independent action that the original 1973 judgment for the defendants should be set aside; the New Mexico Court of Appeals held that the effort was barred because a 2000 federal judgment had already rejected a similar attempt to reopen that same case, so res judicata applied and the dismissal stood. The connection to the Universal Life Church is only indirect: while discussing New Mexico preclusion doctrine, the court cited Three Rivers Land Co. v. Maddoux and noted that it had been “overruled on other grounds by Universal Life Church v. Coxon,” meaning the ULC appears only as background precedent on procedure, not as a party or factual participant in the Cordova dispute.

Reform Congregation Oheb Sholom v. Berks County Bd. of Assessment Appeals (Pennsylvania)

Here a synagogue sought a property-tax exemption for a nearby house where its full-time maintenance employee was required to live so she could respond to alarms, evening events, weekend services, and emergencies, but the Pennsylvania Commonwealth Court held the house was still taxable because it was not an “actual place of regularly stated religious worship” and was not exempt merely because it supported the synagogue’s operations. The case connects to the Universal Life Church only as precedent: in denying the exemption, the court cited "Holland Universal Life Church of Love Appeal", a prior Pennsylvania case holding that even a pastor’s dwelling was not exempt when it was not actually used as a qualifying place of worship, so the ULC was not a party here but appeared as part of the court’s reasoning on church-property tax law.

City of Sunland Park v. Macias (New Mexico)

Here, the City of Sunland Park and related private utility interests sued Doña Ana County to block a county ordinance authorizing revenue bonds for a new county water and sewer system, arguing that the ordinance’s anti-competition provisions were unlawful and threatened to monopolize local utility service. The New Mexico Court of Appeals held that the suit should not have been dismissed on collateral-estoppel or ripeness grounds and sent the case back, concluding the City had stated a legally sufficient claim for injunctive relief under the New Mexico Antitrust Act. The connection to the Universal Life Church is only indirect: in discussing New Mexico claim-preclusion law, the court cited Three Rivers Land Co. v. Maddoux and noted that it had been overruled on other grounds by Universal Life Church v. Coxon, so the ULC appears only as background precedent, not as a party or factual participant in the dispute.

Apodaca v. AAA Gas Co. (New Mexico)

This dispute involves a situation wherein two mechanics were severely burned and a third worker was killed when a propane delivery truck that still contained a large amount of propane exploded while being repaired at a shop. The injured workers sued AAA Gas Company and others, alleging negligence and product-related liability for delivering the truck for repair without properly emptying or securing the propane tank. The New Mexico Court of Appeals addressed procedural and claim-preclusion issues arising from the litigation, including whether certain claims could proceed. The case connects to the Universal Life Church only indirectly: while discussing New Mexico res judicata doctrine, the court cited Three Rivers Land Co. v. Maddoux and noted that it had been “overruled on other grounds by Universal Life Church v. Coxon,” meaning the ULC appears only as cited precedent, not as a party or factual participant in the propane explosion dispute.

Chaara v. Lander (New Mexico)

This dispute arose after tenants of a restaurant property in Santa Fe sued the landlords following a fire that destroyed the building, claiming the landlords’ negligence and other conduct caused the loss of their business and property; the New Mexico Court of Appeals addressed various procedural and substantive issues stemming from the landlord–tenant and tort claims connected to the fire and resulting damages. The case connects to the Universal Life Church only indirectly: while discussing New Mexico claim-preclusion doctrine, the court cited Three Rivers Land Co. v. Maddoux and noted that it had been “overruled on other grounds by Universal Life Church v. Coxon,” meaning the Universal Life Church appears only as background precedent on res judicata procedure and was not involved in the dispute itself.

Custody of Anndre'Ya W. (Connecticut)

This is a Connecticut Juvenile Matters case involving the children Anndre’ya W. and Alexis C.—the court was addressing a child-protection matter rather than any dispute about marriage or church rights; the limited public descriptions available identify it as a Hartford juvenile case concerning the welfare of the children, and the Universal Life Church appears only because the father, Andrew, offered evidence that he had completed Bible-study courses and had been ordained in the Universal Life Church. So the connection to the ULC is incidental: the Church was not a party, and the case did not turn on the legal status of ULC ministers, but simply mentioned the father’s ordination as part of the background evidence before the juvenile court.

Bank of Santa Fe v. Marcy Plaza Assocs. (New Mexico)

Here, a bank (as landlord and trustee of the property owner), tried to stop its tenant Marcy Plaza from pursuing a second arbitration over roughly $34,000 in alleged rent overpayments, arguing that the claim was barred by res judicata because the parties had already arbitrated a different lease dispute in 1996 about whether refinancing costs could be deducted in calculating “net profit.” The New Mexico Court of Appeals held the later claim was not barred, because it involved different facts and a different rent-calculation issue—Marcy Plaza’s mistaken inclusion of tenant pass-through expenses like utilities in gross rental income—rather than the earlier refinancing dispute. The case connects to the Universal Life Church only indirectly: in stating New Mexico’s claim-preclusion test, the court cited Three Rivers Land Co. v. Maddoux and noted that it had been “overruled on other grounds by Universal Life Church v. Coxon,” so the ULC appears only as background precedent on procedure, not as a party or factual participant in the lease dispute.

Safety-Kleen, Inc. v. Wyche (South Carolina)

In this case a Chapter 11 debtor sued South Carolina environmental regulators after a state-court ruling about its Pinewood hazardous-waste landfill effectively left the site at or over its permitted capacity, prompting the state to order the facility closed and to insist on compliance with financial-assurance rules. Safety-Kleen argued that bankruptcy’s automatic stay and various constitutional theories barred the state’s actions, but the Fourth Circuit largely rejected that effort, holding that the state was acting under its environmental police and regulatory powers, so the automatic stay did not prevent enforcement of those requirements. The connection to the Universal Life Church is purely precedential: in analyzing the bankruptcy “police or regulatory power” exception, the Fourth Circuit cited In re Universal Life Church, 128 F.3d 1294 (9th Cir. 1997), for the distinction between government actions serving public policy and those pursuing a pecuniary interest; the Universal Life Church itself had no factual role in the landfill dispute.