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, v. the Church of Christ at Independence, Missouri'') was a

United States The United States of America (U.S.A. or USA), commonly known as the United States (U.S. or US) or America, is a country primarily located in North America. It consists of 50 states, a federal district, five major unincorporated territorie ...

legal case A legal case is in a general sense a dispute between opposing parties which may be resolved by a court, or by some equivalent legal process. A legal case is typically based on either civil or criminal law. In most legal cases there are one or mor ...

in the 1890s which addressed legal ownership of the

Temple Lot The Temple Lot, located in Independence, Missouri, is the first site to be dedicated for the construction of a temple in the Latter Day Saint movement. The area was dedicated on August 3, 1831, by the movement's founder, Joseph Smith Jr., and p ...

, a significant parcel of land in the

Latter Day Saint movement The Latter Day Saint movement (also called the LDS movement, LDS restorationist movement, or Smith–Rigdon movement) is the collection of independent church groups that trace their origins to a Christian Restorationist movement founded by Jo ...

. In the case, the

Reorganized Church of Jesus Christ of Latter Day Saints The Community of Christ, known from 1872 to 2001 as the Reorganized Church of Jesus Christ of Latter Day Saints (RLDS), is an American-based international church, and is the second-largest denomination in the Latter Day Saint movement. The churc ...

(RLDS Church, now Community of Christ) claimed legal title of the land and asked the court to order the

Church of Christ (Temple Lot) The Church of Christ, informally called Hedrickites and the Church of Christ (Temple Lot), is a denomination of the Latter Day Saint movement headquartered in Independence, Missouri, on what is known as the Temple Lot. The nickname for members of ...

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

is a small parcel of land in

Independence, Missouri Independence is the fifth-largest city in Missouri and the county seat of Jackson County, Missouri, Jackson County. Independence is a satellite city of Kansas City, Missouri, and is the largest suburb on the Missouri side of the Kansas City metro ...

. In the early 1830s, the lot was designated by

Joseph Smith Joseph Smith Jr. (December 23, 1805June 27, 1844) was an American religious leader and founder of Mormonism and the Latter Day Saint movement. When he was 24, Smith published the Book of Mormon. By the time of his death, 14 years later, he ...

as the site for a proposed

temple A temple (from the Latin ) is a building reserved for spiritual rituals and activities such as prayer and sacrifice. Religions which erect temples include Christianity (whose temples are typically called churches), Hinduism (whose temples ...

for a prophesied city of "Zion" or "New Jerusalem". In 1831, Latter Day Saint

Bishop A bishop is an ordained clergy member who is entrusted with a position of authority and oversight in a religious institution. In Christianity, bishops are normally responsible for the governance of dioceses. The role or office of bishop is ca ...

Edward Partridge Edward Partridge Sr. (August 27, 1793 – May 27, 1840) was one of the earliest converts to the Latter Day Saint movement and served as the first Bishop of the Church. Early life Edward Partridge was born on August 27, 1793 to William and Jem ...

purchased the Temple Lot from Jones H. Flournoy and Clara Flournoy on behalf of Smith's Latter Day Saint church.S. Patrick Baggette, II,
"The Temple Lot Case: Fraud in God's Vinyard"
''John Whitmer Historical Association Journal'' 23 (2003): 121–136. Partridge held the property in trust for the church. The proposed temple was never built on the site and the

Latter Day Saint The Latter Day Saint movement (also called the LDS movement, LDS restorationist movement, or Smith–Rigdon movement) is the collection of independent church groups that trace their origins to a Christian Restorationist movement founded by Jo ...

s were ultimately driven out of

Missouri Missouri is a U.S. state, state in the Midwestern United States, Midwestern region of the United States. Ranking List of U.S. states and territories by area, 21st in land area, it is bordered by eight states (tied for the most with Tennessee ...

. 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

(the "Hedrickites") ultimately found themselves in possession of the most prominent portion of the 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

the Church of Jesus Christ of Latter-day Saints The Church of Jesus Christ of Latter-day Saints, informally known as the LDS Church or Mormon Church, is a Nontrinitarianism, nontrinitarian Christianity, Christian church that considers itself to be the Restorationism, restoration of the ...

(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 Missouri The United States District Court for the Western District of Missouri (in case citations, W.D. Mo.) is the federal judicial district encompassing 66 counties in the western half of the State of Missouri. The Court is based in the Charles Evans ...

claiming equitable title to the Temple Lot, which was under the control by the Temple Lot church.''Reorganized Church of Jesus Christ of Latter Day Saints v. Church of Christ'', 60 F. 937 (C.C.W.D. Mo. 1894). After Joseph Smith's death, the Latter Day Saint movement had splintered into a number of separate churches; Smith's son

Joseph Smith III Joseph Smith III (November 6, 1832 – December 10, 1914) was the eldest surviving son of Joseph Smith (founder of the Latter Day Saint movement) and Emma Hale Smith. Joseph Smith III was the Prophet-President of what became the Reorganized Chu ...

was the

president President most commonly refers to: *President (corporate title) *President (education), a leader of a college or university *President (government title) President may also refer to: Automobiles * Nissan President, a 1966–2010 Japanese ful ...

of the RLDS Church and claimed that the RLDS Church was the rightful successor to the original Latter Day Saint church.Ron Romig, "The Temple Lot Suit After 100 Years", ''John Whitmer HIstorical Association Journal'' 12 (1992): 3–15. 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 A conference is a meeting of two or more experts to discuss and exchange opinions or new information about a particular topic. Conferences can be used as a form of group decision-making, although discussion, not always decisions, are the main p ...

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 The ''Chicago Tribune'' is a daily newspaper based in Chicago, Illinois, United States, owned by Tribune Publishing. Founded in 1847, and formerly self-styled as the "World's Greatest Newspaper" (a slogan for which WGN radio and television ar ...

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.

Appeal

The Church of Christ (Temple Lot) appealed the trial court's decision to the

United States Court of Appeals for the Eighth Circuit The United States Court of Appeals for the Eighth Circuit (in case citations, 8th Cir.) is a United States federal court with appellate jurisdiction over the following United States district courts: * Eastern District of Arkansas * Western Dis ...

.''Church of Christ in Missouri v. Reorganized Church of Jesus Christ of Latter Day Saints'', 70 F. 179 (8th Cir. 1895). 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 by the Court of Appeals

en banc In law, an en banc session (; French for "in bench"; also known as ''in banc'', ''in banco'' or ''in bank'') is a session in which a case is heard before all the judges of a court (before the entire bench) rather than by one judge or a smaller ...

but the motion was dismissed. The RLDS Church then sought to appeal the decision to the

United States Supreme Court The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all U.S. federal court cases, and over state court cases that involve a point o ...

, but that court denied

certiorari In law, ''certiorari'' is a court process to seek judicial review of a decision of a lower court or government agency. ''Certiorari'' comes from the name of an English prerogative writ, issued by a superior court to direct that the record of ...

,''Reorganized Church of Jesus Christ of Latter Day Saints v. Church of Christ'', 163 U.S. 681 (1896). 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 Israel Alexander Smith (February 2, 1876 – June 14, 1958) was the fourth son of Joseph Smith III and a grandson of Joseph Smith Jr., the founder of the Latter Day Saint movement. Israel A. Smith succeeded his brother, Frederick M. Smith, as ...

, 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.

Impact

The case became an important source for documents related to Mormon plural marriage. To counteract RLDS claims to be the true successors to Joseph Smith Jr., the LDS Church assisted by having women give court testimony about their polygamist relationships with him.

Notes

References

*''The Temple Lot Case''

rial and appeal transcripts Rial, riyal, or RIAL may refer to: * Rial (surname), a surname (and list of people with the name) * Royal Institution for the Advancement of Learning, McGill University * Rial Racing, a former German Formula One team Various currencies named ria ...

(Lamoni, Iowa: Herald Publishing House, 1893) *Bert C. Flint, ''An Outline History of the Church of Christ (Temple Lot)'' (Independence, Mo.: Church of Christ, Temple Lot, 1979)

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" * *{{cite web , title=Intro to Church of Christ (Temple Lot)— part 1 of 7 , url=https://gospeltangents.com/2020/02/intro-temple-lot/ , website= Gospel Tangents , access-date=17 October 2021 , date=28 February 2020 , quote=Interview with Jean Addams 1894 in United States case law 1895 in United States case law Community of Christ History of the Latter Day Saint movement Independence, Missouri Latter Day Saint movement in Missouri Mormonism and law Mormonism-related controversies United States Court of Appeals for the Eighth Circuit cases Law articles needing an infobox Temple Lot 1894 in Christianity 1895 in Christianity Church of Christ (Temple Lot) 19th-century Mormonism 1895 in Missouri Christianity and law in the 19th century