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See also: "Homosexuality and Anglicanism

The Episcopal Church affirmed at the 1976 General Convention that "homosexuals are "children of God" who deserve acceptance and pastoral care from the church. It also called for homosexual persons to have equal protection under the law. This was reaffirmed in 1982. Despite these affirmations of "gay rights, the General Convention affirmed in 1991 that "physical sexual expression" is only appropriate within the "monogamous, lifelong "union of husband and wife".[37] In 1994, the GC determined that church membership would not be determined on "marital status, sex, or sexual orientation".

The first openly gay priest, Robert Williams, was ordained by "John Shelby Spong in 1989.[38] The ordination provoked a furor. The next year Barry Stopfel was ordained a deacon by Spong's assistant, Walter Righter. Because Stopfel was not celibate, this resulted in a trial under "canon law. The church court dismissed the charges on May 15, 1996, stating that "no clear doctrine"[39] prohibits ordaining a gay or lesbian person in a committed relationship.[40]

21st century Anglican issues[edit]

Gay and lesbian access to marriage and the episcopate[edit]

Homosexuality and Anglicanism

The first openly homosexual bishop, "Gene Robinson, was elected on June 7, 2003, at St. Paul's Church in "Concord, New Hampshire. Thirty-nine clergy votes and 83 lay votes was the threshold necessary to elect a bishop in the "Episcopal Diocese of New Hampshire at that time. The clergy voted 58 votes for Robinson and the laity voted 96 for Robinson on the second ballot. Consent to the election of Robinson was given at the 2003 General Convention. The House of Bishops voted in the affirmative, with 62 in favor, 43 opposed, and 2 abstaining. The House of Deputies, which consists of laypersons and priests, also voted in the affirmative: the laity voted 63 in favor, 32 opposed, and 13 divided; the clergy voted 65 in favor, 31 opposed, and 12 divided.

In response, a "meeting of the Anglican primates (the heads of the Anglican Communion's 38 member churches) was convened in October 2003, which warned that if Robinson's consecration proceeded, it could "tear the fabric of the communion at its deepest level."[41] The primates also appointed a commission to study these issues, which issued the "Windsor Report the following year. At the request of the commission issuing the Windsor Report, the Episcopal Church released To Set Our Hope on Christ on June 21, 2005, which explains "how a person living in a same gender union may be considered eligible to lead the flock of Christ."[42]

Robinson was consecrated on November 2, 2003, in the presence of Frank Griswold, the Presiding Bishop, and 47 bishops.[43]

The General Convention of 2003 also passed a resolution discouraging the use of "conversion therapy to attempt to change "homosexuals into "heterosexuals.[44]

In 2009, the General Convention responded to societal, political and legal changes in the status of "civil marriage for same-sex couples by giving bishops an option to provide "generous pastoral support" especially where civil authorities have legalized same-gender marriage, civil unions, or domestic partnerships. It also charged the Standing Commission on Liturgy and Music to develop theological and liturgical resources for same-sex blessings and report back to the General Convention in 2012.[45]

The same General Convention also voted that "any ordained ministry" is open to gay men and lesbians.[46] "The New York Times said the move was "likely to send shockwaves through the Anglican Communion."[47] This vote ended a moratorium on ordaining gay bishops passed in 2006 and passed in spite of Archbishop "Rowan Williams's personal call at the start of the convention that, "I hope and pray that there won't be decisions in the coming days that will push us further apart."[46] A noted "Evangelical scholar of the "New Testament, "N. T. Wright, who is also "Bishop of Durham in the "Church of England, wrote in "The Times (London) that the vote "marks a clear break with the rest of the Anglican Communion" and formalizes the Anglican schism.[48] However, in another resolution the Convention voted to "reaffirm the continued participation" and "reaffirm the abiding commitment" of the Episcopal Church with Anglican Communion.[49]

A woman as Presiding Bishop[edit]

The 2006 election of Jefferts Schori as the Church's 26th presiding bishop was controversial in the wider Anglican Communion because she is a woman and the full Anglican communion does not recognize the ordination of women. She is the only national leader of a church in the Anglican Communion who is a woman. Prior to her election she was "Bishop of Nevada. She was elected at the 75th General Convention on June 18, 2006, and invested at the "Washington National Cathedral on November 4, 2006.

Jefferts Schori generated controversy when she voted to confirm openly gay Gene Robinson as a bishop and for allowing "blessings of same-sex unions in her diocese of Nevada.

During her time as Presiding Bishop, ten "primates of the Anglican communion stated that they did not recognize Jefferts Schori as a primate.["citation needed] In addition, eight American dioceses rejected her authority and asked "Archbishop of Canterbury "Rowan Williams to assign them another national leader.[50]

Conservative reactions to these developments[edit]

These innovations have been responded to in various ways. The opposition to Ritualism produced the "Reformed Episcopal Church in 1873. Opposition to the ordination of women priests and to theological revisions incorporated into the Episcopal Church's 1979 Book of Common Prayer led to the formation of the "Continuing Anglican movement in 1977; and opposition to the consecration of the first ever openly homosexual bishop led to the creation of the "Anglican Church in North America. It officially organized in 2009, forming yet another ecclesiastical structure apart from the Episcopal Church.[51][51][52] This grouping, which reported at its founding that it represented approximately 100,000 Christians through its over 700 parishes, elected former Episcopal "Robert Duncan as its primate.[47][51][52] The ACNA has not been received as an official member of the "Anglican Communion by the Church of England, and is not in communion with the see of Canterbury, but many Anglican churches of the "Global South, such as the "Church of Nigeria and "Church of Uganda, together representing approximately 1/3 of the worldwide Anglican Communion, have declared themselves to be in full communion with it.

The two main movements in opposition to the developments within the Episcopal Church are generally referred to as the "Continuing Anglican movement and "Anglican realignment.

Secession and realignment[edit]

Anglican realignment

In 1977, 1,600 bishops, clergy and lay people met in St. Louis and formed the "Congress of St. Louis under the leadership of retired Episcopal bishop Albert Chambers.[53] This began the Continuing Anglican Movement with the adoption of the "Affirmation of St. Louis. Many other conservative groups have continued to break away out of frustration over the Church's position on homosexuality, the ordination of openly homosexual priests and bishops, and abortion — or rather, the way the Episcopal Church has viewed the place of Scripture in determining doctrine on those issues. In addition to those which have affiliated with one of the Continuing Anglican churches or the Anglican Church in North America, there are also congregations that have joined one of the Eastern Orthodox jurisdictions, "Old Catholicism, or the "Roman Catholic Church.

Five diocesan conventions have voted to withdraw from the Episcopal Church: the Diocese of San Joaquin, the Diocese of Fort Worth, the Diocese of Quincy, the Diocese of Pittsburgh, and the Diocese of South Carolina. This does not include individual congregations that have also withdrawn, as in the "Diocese of Virginia where members of eight parishes voted to leave the Episcopal Church. Included were the historic "Falls Church and "Truro Church. These congregations then formed the "Anglican District of Virginia, which became part of the "Convocation of Anglicans in North America (CANA).

The first diocesan convention to vote to break with the Episcopal Church (which has 110 dioceses) was the "Episcopal Diocese of San Joaquin.[54] On December 8, 2007, the convention of the Episcopal Diocese of San Joaquin voted to secede from the Episcopal Church and join the "Anglican Province of the Southern Cone, a more conservative and traditional member of the Anglican Communion located in South America.[55] The diocese had 48 parishes. A minority of parishes and individuals reorganized the diocese and remained in the Episcopal Church. [56] On July 21, 2009, the Superior Court of California ruled that the diocese cannot leave the Episcopal Church and that these acts were void, however, not until 2016 was litigation fully resolved and did those who remained in the Episcopal Church gain control of the property.[57] On October 4, 2008, the convention of the "Episcopal Diocese of Pittsburgh also voted to leave the Episcopal Church and join the Province of the Southern Cone. This split occurred after the "House of Bishops, "deposed Robert Duncan from office in September 2008. Duncan had led the diocese for 11 years.[58] One third of the parishes and members of the Pittsburgh Diocese remained in the Episcopal Church and had received recognition as the Episcopal Diocese within a week of the convention vote.[59]

The conventions of the "Diocese of Quincy in Illinois and the "Diocese of Fort Worth voted in November 2008 to leave the Episcopal Church.[58] On November 15, 2008, the convention of the "Diocese of Fort Worth, under the leadership of "Jack Leo Iker and with the vote of 80 percent of the voting clergy and laity, also voted to align with the Province of the Southern Cone.[60] As in the earlier cases, the remaining Episcopalians reorganized as a diocese. In response to the departure of Iker and the Fort Worth diocese, Jefferts Schori declared that Iker had "abandoned the communion" and joined with the local diocese in suing Iker and followers, seeking to reclaim church buildings and property.[61] On November 16, 2009, the appellate court issued an order staying the litigation while certain procedural issues were decided by the appellate court.[62] On April 27, 2010, the Second Court of Appeals in Fort Worth heard oral argument on issues that may determine whether the litigation will be allowed to proceed at the trial level.[63]

Two years later the Episcopal Diocese of South Carolina declared that an earlier vote by their Standing Committee was now in effect and that they had left the Episcopal Church. The Diocese then held a special convention in November 2012 to affirm that action. However, Bishop Lawrence and his followers did not immediately join the Anglican Church of North America and remained a free standing diocese. They almost immediately sued in South Carolina Courts, claiming they were doing so to protect their property. The court ordered those staying in the Episcopal Church to refrain from calling themselves the Diocese of South Carolina. That group then sued in federal court to recover their name. Both the state court case and the federal case remain in litigation.[64]

Jefferts Schori has criticized these moves and stated that "schism is not an "honored tradition within Anglicanism" and claims schism has "frequently been seen as a more egregious error than charges of "heresy."[58] In Pittsburgh one member of the Standing Committee remained in the Episcopal Church and some members of each of the other governing bodies also remained. Those remaining in the Episcopal Church were recognized immediately by the Presiding Bishop and executive Council of the Episcopal Church as the continuation of the old diocese and began rebuilding without further help from the church.[65] A lawsuit filed in 2003, settled in 2005, reopened in 2007 and decided 2009 with final appeals in 2010 awarded the name and diocesan property to those who remained in the Episcopal Church in Pittsburgh.[66] In the other four dioceses diocese where parishioners have voted to leave, the Presiding Bishop provided interim listeners and presided at an organizing convention. In all four cases, both those who left the Episcopal Church and those who remained claimed that their organizations were the "real" Episcopal Diocese. In 2016 the California Supreme Court refused to review lower court rulings recognizing those who had remained in the Episcopal Church as the legal owners of the property and name. Courts in Illinois ruled against the Episcopalians and awarded the property to the ACNA diocese.

Church property litigation[edit]

In 1993, the Connecticut Supreme Court concluded that former parishioners of a local Episcopal church could not keep the property held in the name of that parish because it found that a relationship existed between the local and general church such that a legally enforceable trust existed in favor of the general church over the local church's property.[67]

On December 19, 2008, a Virginia trial court ruled that eleven congregations of former Episcopalians could keep parish property when the members of these congregations split from the Episcopal church to form the "Anglican District of Virginia (ADV).[68] The Episcopal Church claimed that the property belonged to it under the canon law of the Episcopal Church after appeals reached the Virginia Supreme Court, a new trial was ordered which resulted in a decision returning the property to the Episcopal Church.[69] Subsequent appeals by those who had left the Episcopal Church were unsuccessful including an appeal by one parish to the U.S. Supreme Court in 2014.[70]

Other rulings in Colorado and California have ordered congregations that have voted to change their associations within the Anglican Communion to return their properties to the Episcopal Church.[71] On January 5, 2009, the California Supreme Court ruled that "St. James Anglican Church in "Newport Beach could not keep property held in the name of an Episcopal parish. The court concluded that even though the local church's names were on the property deeds for many years, the local churches had agreed to be part of the general church.[72]

Property litigation in Pittsburgh began before the split when Calvary Episcopal Church filed suit against Duncan in 2003 in order to ensure diocesan property remained in the Episcopal Church. A second parish, St. Stephen's in Wilkinsburg later joined Calvary as a plaintiff. This resulted in a signed stipulation specifying that diocesan property would remain the property of the Episcopal Diocese of Pittsburgh in the Episcopal Church U.S.A.,[73] In 2009, the Judge of the Court of Common Pleas ruled that the 2005 agreement signed by Duncan to settle the Lawsuit brought by Calvary Church meant that diocesan property belonged to those remaining in the Episcopal Church.[74] This was confirmed in January 2010 with a decision including a schedule of property to be returned.[75] The group that left changed its name to the Anglican Diocese of Pittsburgh, but appealed the decision. In 2011, a panel of judges from the appellate court in Pennsylvania affirmed that ruling, and the full appellate court declined to review the ruling.[74] The state supreme court also declined to hear an appeal.[76] The Anglican Diocese of Pittsburgh announced that it would not pursue further appeals.

References[edit]

Those interested in the history might wish to visit the "Historical Society of the Episcopal Church or "National Episcopal Historians and Archivists (NEHA)

  1. ^ Sydnor, William (1980). Looking at the Episcopal Church. USA: Morehouse Publishing. p. 64. 
  2. ^ a b c Sydnor, William (1980). Looking at the Episcopal Church. USA: Morehouse Publishing. p. 72. 
  3. ^ Roozen, David A.; James R. Nieman, Editors (2005). Church, Identity, and Change: Theology and Denominational Structures in Unsettled Times. Grand Rapids, Michigan: William B. Eerdmans Publishing Company. "ISBN 0-8028-2819-1. p. 188.
  4. ^ a b c Carrington, Philip (1963). The Anglican Church in Canada. Toronto: Collins. 
  5. ^ Olmstead, Clifton E. (1960). History of Religion in the United States. Englewood Cliffs, N.J.: Prentice-Hall. p. 45. 
  6. ^ New York Gazette or Weekly Post Boy, March 14, 1768
  7. ^ a b Bonomi, Patricia U. (13 November 1986). Under the Cope of Heaven: Religion, Society, and Politics in Colonial America. New York, New York: Oxford University Press. "ISBN "0195041186. 
  8. ^ James B. Bell. A War of Religion: Dissenters, Anglicans, and the American Revolution (2008)
  9. ^ a b c d e f g h i j k l m n o p q r s t u v w x y z aa ab ac ad ae af ag ah Hein, David; Gardiner H. Shattuck Jr (2004). The Episcopalians. New York: Church Publishing. "ISBN "0-89869-497-3. 
  10. ^ McConnell 2003
  11. ^ Thomas E. Buckley, "Evangelicals Triumphant: The Baptists' Assault on the Virginia Glebes, 1786–1801," William and Mary Quarterly, January 1988, Vol. 45 Issue 1, pp 33-70 in JSTOR
  12. ^ a b Roozen 2005, p. 189.
  13. ^ Podmore, Colin (May 2008). "A Tale of Two Churches: The Ecclesiologies of The Episcopal Church and the Church of England Compared". International Journal for the Study of the Christian Church. 8 (2): 135. "doi:10.1080/14742250801930822. 
  14. ^ Edward L. Bond and Joan R. Gundersen (2007), "The Episcopal Church in Virginia, 1607–2007", Virginia Magazine of History & Biography 115, no. 2: Chapter 2.
  15. ^ Piepkorn, Arthur Carl (1977). Profiles in Belief: The Religious Bodies of the United States and Canada. Harper & Row. p. 199. "ISBN "0-06-066580-7. 
  16. ^ a b Robert Bruce Mullin, "The Office of Bishop among Episcopalians, 1780–1835," Lutheran Quarterly, Spring 1992, Vol. 6 Issue 1, pp 69-83
  17. ^ "Constitution of the Domestic and Foreign Missionary Society," in Journal of the Proceedings of the Bishops, Clergy, and Laity of the Protestant Episcopal Church in the United States of America in General Convention'(New York: Protestant Episcopal Press, 1835): 129.
  18. ^ Roozen 2005, p. 190.
  19. ^ "UBE History". Ube.org. Archived from the original on October 13, 2007. Retrieved 2008-11-16. 
  20. ^ Lockert B. Mason, "Separation and Reunion of the Episcopal Church, 1860–1865: The Role of Bishop Thomas Atkinson," Anglican and Episcopal History, September 1990, Vol. 59 Issue 3, pp 345-365
  21. ^ a b c d Roozen 2005, p. 191.
  22. ^ "UBE History". Episcopalchurch.org. Archived from the original on 2008-07-10. Retrieved 2008-11-16. 
  23. ^ Diana Hochstedt Butler, Standing against the Whirlwind: Evangelical Episcopalians in Nineteenth-Century America (1995)
  24. ^ Roozen 2005, pp. 191–192.
  25. ^ "Episcopal Shield". Kingofpeace.org. Retrieved 2008-11-16. 
  26. ^ Peter W. Williams, "The Gospel of Wealth and the Gospel of Art: Episcopalians and Cultural Philanthropy from the Gilded Age to the Depression", Anglican and Episcopal History, June 2006, Vol. 75 Issue 2, pp170–223
  27. ^ The Archbishop of Canterbury's Presidential Address, paragraph 5. Archived August 20, 2007, at the "Wayback Machine.
  28. ^ "News Coverage from the 75th General Convention of the Episcopal Church". Episcopalchurch.org. Archived from the original on 2011-01-17. Retrieved 2010-11-28. 
  29. ^ http://www.episcopalarchives.org/cgi-bin/the_living_church/TLCarticle.pl?volume=210&issue=9&article_id=1
  30. ^ "Frum, David (2000). How We Got Here: The '70s. New York, New York: Basic Books. p. 17. "ISBN "0-465-04195-7. 
  31. ^ The Archives of the Episcopal Church, Acts of Convention: Resolution #1991 B051, Call for the Removal of Racism from the Life of the Nation. Retrieved 2008-10-31.
  32. ^ Bishops Endorse Apology for Slavery Complicity Archived September 27, 2007, at the "Wayback Machine.
  33. ^ The Philadelphia Eleven, and the consecrating bishops, are listed in the Philadelphia 11 article on The Episcopal Church website. Retrieved November 5, 2006.
  34. ^ The Archives of the Episcopal Church, Acts of Convention: Resolution #1976-B300, Express Mind of the House of Bishops on Irregularly Ordained Women. Retrieved 2008-10-31.
  35. ^ Harris is also the first African-American woman to be consecrated as bishop. Office of Black Ministries, The Episcopal Church Archived 2009-08-08 at the "Wayback Machine.
  36. ^ The Archives of the Episcopal Church, Acts of Convention: Resolution #1997-A053, Implement Mandatory Rights of Women Clergy under Canon Law. Retrieved 2008-10-31.
  37. ^ The Archives of the Episcopal Church, Acts of Convention: Resolution #1991-A104, Affirm the Church's Teaching on Sexual Expression, Commission Congregational Dialogue, and Direct Bishops to Prepare a Pastoral Teaching. Retrieved 2008-10-31.
  38. ^ "''A Bishop Speaks: Homosexual History'' by John Shelby Spong, retrieved November 4, 2006". Beliefnet.com. Retrieved 2008-11-16. 
  39. ^ "The Episcopal Church And Homosexuality: Activities during 1996". Religioustolerance.org. Retrieved 2008-11-16. 
  40. ^ Anglicans Online: The Trial of Bishop Walter Righter.
  41. ^ Anglican Communion News Service Archived September 30, 2007, at the "Wayback Machine.
  42. ^ Theologians offer response to Windsor Report request: Paper cites 40-year consideration of same-gender relationships from Episcopal News Service.
  43. ^ Adams, Elizabeth (2006). Going to Heaven: The Life and Election of Bishop Gene Robinson. Brooklyn, NY: Soft Skull Press. "ISBN "1-933368-22-5. 
  44. ^ The Archives of the Episcopal Church, Acts of Convention: Resolution #2003-C004, Oppose Certain Therapies for Sexual Orientation. 2008-10-31.
  45. ^ 76th General Convention Legislation, Resolution C056 Archived 2012-04-24 at the "Wayback Machine.. Retrieved August 18, 2010.
  46. ^ a b Laurie Goodstein,Episcopal Vote Reopens a Door to Gay Bishops, "The New York Times, July 14, 2009. Retrieved on July 21, 2009.
  47. ^ a b Goodstein, Laurie (2009-07-15). "Episcopal Vote Reopens a Door to Gay Bishops". The New York Times. Retrieved 2010-05-02. 
  48. ^ "Tom Wright, The Americans know this will end in schism—Support by US Episcopalians for homosexual clergy is contrary to Anglican faith and tradition. They are leaving the family, "The Times, July 15, 2009. Retrieved on July 21, 2009.
  49. ^ "Resolution D025". Gc2009.org. Retrieved 2010-11-28. 
  50. ^ "Episcopal Diocese of Quincy seeks alternative oversight". Episcopalchurch.org. Archived from the original on 2008-11-12. Retrieved 2008-11-16. 
  51. ^ a b c "Rick Warren to address breakaway Anglicans". 
  52. ^ a b "Pastor Rick Warren, Metropolitan Jonah, the Rev. Dr. Todd Hunter to Address ACNA Assembly". 
  53. ^ "News & Announcements". Anglicancatholic.org. Retrieved 2008-11-16. 
  54. ^ Goodstein, Laurie; Marshall, Carolyn (2006-12-03). "Episcopal Diocese Votes to Secede From Church". The New York Times. Retrieved 2010-05-02. 
  55. ^ Role of gays prompts split in Episcopal Church, AP/CNN, December 8, 2007
  56. ^ "Episcopal Diocese Votes to Secede From Church", an article in The New York Times by Laurie Goodstein and Carolyn Marshall, December 3, 2006
  57. ^ http://s3.amazonaws.com/dfc_attachments/public/documents/356/Order-MSA.PDF; "California Supreme Court Upholds Ruling in San Joaquin Property Case," http://episcopaldigitalnetwork.com/ens/2016/07/14/california-supreme-court-upholds-ruling-in-san-joaquin-property-case/
  58. ^ a b c Joe Mandak, Associated Press (2008-10-06). "Pittsburgh diocese votes to split from Episcopal Church — USATODAY.com". Usatoday.com. Retrieved 2008-11-16. 
  59. ^ http://www.episcopalchurch.org/library/article/pittsburgh-votes-leave-episcopal-church-align-southern-cone
  60. ^ Terry Lee Goodrich (November 15, 2008). "Fort Worth Episcopal Diocese votes to leave mother church". Fort Worth Star-Telegram. 
  61. ^ S.G. Gwynne (1 February 2010). "Bishop takes Castle". "Texas Monthly. Retrieved 2 May 2010. 
  62. ^ In re: Franklin Salazar et al. (2nd Court of Appeals, Fort Worth 16 November 2009). Text
  63. ^ "Oral argument In re: Salazar et al". Second Court of Appeals, Fort Worth. 27 April 2010. Retrieved 2 May 2010. 
  64. ^ "Law Meets Religion as SC Supreme Court Takes on Episcopal Split" http://www.thestate.com/news/local/article36286839.html
  65. ^ http://www.post-gazette.com/frontpage/2008/10/10/Minority-recognized-as-true-Episcopal-Diocese/stories/200810100232
  66. ^ Harold Lewis, The Recent Unpleasantness: Calvary Church's Role in the Preservation of the Episcopal Church in the Diocese of Pittsburgh, Eugene OR: Wipf and Stock, 2015.
  67. ^ Rector, Wardens v. Episcopal Church 620 A.2d 1280, 1293 (Conn. 1993) The court stated the local church “had agreed, as a condition to their formation as ecclesiastical organizations affiliated with the Diocese and [the Episcopal Church], to use and hold their property only for the greater purposes of the church.” (Id. at p. 1292.) Specifically an Episcopal Church law, (which it called the “Dennis Canon”), “adopted in 1979 merely codified in explicit terms a trust relationship that has been implicit in the relationship between local parishes and dioceses since the founding of [the Episcopal Church] in 1789.” (Ibid.) Accordingly, it found “a legally enforceable trust in favor of the general church in the property claimed by the [local church].”
  68. ^ "News — Exclusives — FAIRFAX, Va.: Anglican District of Virginia Wins Church Property Case". VirtueOnline. Retrieved 2010-11-28. 
  69. ^ http://www.thediocese.net/News/newsView.asp?NewsId=40968295
  70. ^ http://www.thediocese.net/News/newsView.asp?NewsId=40968342
  71. ^ "Judge Schwartz Order on Grace Church" (PDF). Public Record. Retrieved 2009-03-26. ; see also, http://www.courtinfo.ca.gov/opinions/revpub/D051120.PDF
  72. ^ In re Episcopal Church Cases, Case No. S155094 This decision took numerous arguments into account, including court rulings on similar Episcopal Church cases in other states: "Other Episcopal Church cases reaching similar conclusions include: Bishop and Diocese of Colorado v. Mote (Colo. 1986) 716 P.2d 85; Episcopal Diocese of Mass. v. Devine (Mass.App.Ct. 2003) 797 N.E.2d 916 (relying on Canon I.7.4 and the fact the local church had agreed to accede to the general church’s canons); Bennison v. Sharp (Mich.Ct.App. 1983) 329 N.W.2d 466; Protestant Episc. Church, etc. v. Graves (N.J. 1980) 417 A.2d 19; The Diocese v. Trinity Epis. Church (App.Div. 1999) 684 N.Y.S.2d 76, 81 (“[T]he ‘Dennis Canon’ amendment expressly codifies a trust relationship which has implicitly existed between the local parishes and their dioceses throughout the history of the Protestant Episcopal Church,” citing Rector, Wardens v. Episcopal Church, supra, 620 A.2d 1280); Daniel v. Wray (N.C.Ct.App. 2003) 580 S.E.2d 711 (relying on Canon I.7.4); In re Church of St. James the Less (Pa. 2005) 888 A.2d 795 (relying on Canon I.7.4 and citing Rector, Wardens v. Episcopal Church, supra, 620 A.2d 1280)."
  73. ^ http://deimel.org/commentary/b_pages/stipulation.pdf
  74. ^ a b http://www.pitanglican.org/media/courtorder100609.pdf
  75. ^ http://episcopaldiocesefortworth.org/judge-orders-property-returned-to-episcopal-diocese-of-pittsburgh/
  76. ^ http://www.pitanglican.org/media/PA_Supreme_Court_Appeal_rejection.pdf

Further reading[edit]

Historiography[edit]

Primary sources[edit]

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