Legal status of the Universal Life Church

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Since its inception, the Universal Life Church has come into legal conflicts over such issues as the validity of ordinations and the tax-exempt status of the organization.


In 2002 the Church sued the state of Utah regarding the legality of its Internet-based ordination process. Utah had passed a law banning ministers ordained by mail or over the Internet from officiating legal marriage. The court ruled in favor of the Church, declaring the statute unconstitutional and permanently barring the state from enforcing it, noting among other things that there is essentially no difference between an Internet-based application or mail-order application and one sent by courier, fax machine, phone, or done in person. Had the law been allowed to stand, it might well have had the unintended consequence of "defrocking" many ministers from traditional churches for purposes of officiating marriage, for the ULC is not the only church to conduct such business via U.S. Mail.

The United States government was, for a period of time, concerned that perhaps the Church had been founded as a way for Hensley to avoid paying taxes. In 1985, the ULC began a series of court battles against the IRS to prove its legitimacy as a Church. The courts ruled that like any tax-exempt organization, the ULC would qualify for exempt status year by year, based on its financial activities within the tax period. The ULC was subsequently found to be tax-exempt for some years and not in others. Tax exemption can apply only to organizations and not to individual ministers. Each congregation within the ULC is legally independent and would be required to establish its own exemption via 501(c)3 or rely on existing tax statutes to determine tax-exempt status without regard to the Headquarters or any other ULC entity. The three main ULC sites are not currently 501(c)3.

Another common criticism of ULC ordination is that some people, usually as a joke, submit ordination requests for their pets.[1] The ULC has tried to curb the ordination of pets, but if the name on the application appears to be legitimate, the pet will probably receive ordination. The ULC website contains the following warning against fraudulent ordination requests, including attempts to ordain pets:

"No one is rejected because of their name, but we must protect the integrity of the records against those who fraudulently submit requests for pets, obscene names, etc. Applying for ordination in the name of a fictitious person or animal, or the submission of a person's name without his or her permission is fraud, and may subject you to prosecution!"

Court cases in the United States[edit]




North Carolina[edit]

  • State of North Carolina v. Lynch (December 1980) State convicts person married by ULC minister of bigamy in second marriage, then overturned on appeal due to the marriage by the ULC minister being found as not a legal marriage.
  • Fulton v. Vickery (March 1985) Marriage by ULC minister upheld since marriage occurred prior to July 3, 1981 (see NC § 51-1.1)
  • Lynch v. Universal Life Church (October 1985) Individual accuses ULC of fraud; church wins in district court.
  • ULC marriages prior to July 3, 1981 are validated. (NC § 51-1.1.) Marriages solemnized after July 3, 1981 are questionable in legality due to the above case law.

New York[edit]

  • Ranieri v Ranieri Marriage annulled on basis that ULC minister lacked qualifications under New York Statutes: no congregation and not appointed by head of ecclesiastical order.
  • Ravenal v Ravenal Marriage annulled on basis ULC minister lacked actual church or stated meeting place.
  • Rubino v City of New York New York City right to deny license to ULC ministers upheld.
  • Oswald v Oswald Oswald v. Oswald does not hold that ULC ministers can perform marriages in New York. The case was remanded to the trial (Supreme) court because the appellate court determined there was material issues of fact and the summary judgment annulling the marriage should not have been granted. Whether New York recognizes the ULC as a legitimate religious organization, or its ministers, is still a question of fact in the Third Judicial Department, at least until the issue can be litigated at trial.


  • "O'Neill v Bucks County" (PDF).  (1.45 MB) Judge affirms the right for ULC ministers to officiate marriages. Only valid in Bucks County.



  • Cramer v Commonwealth of Virginia The Supreme Court of Virginia held that a trial court did not err by rescinding the authority of ULC "ministers" to perform marriages based on Virginia Code section 20-23. The Court stated: "[w]e do not believe that the General Assembly ever intended to qualify, for licensing to marry, a minister whose title and status could be so casually and cavalierly acquired." 214 Va. 561, 567 (1974).

Opinions of state attorneys general[edit]

See also[edit]

  • Robert E. Rains, Marriage in the Time of Internet Ministers: I Now Pronounce You Married, but Who Am I to Do So?, 64 U. Miami L. Rev. 809 (2010)
  • Bruce J. Casino, I Know It When I See It': Mail-Order Ministry Tax Fraud and the Problem of A Constitutionally Acceptable Definition of Religion, 25 Am. Crim. L. Rev. 113 (1987)
  • Alexandra Marin, Internet-Ordained Ministers and Marriage in Pennsylvania: Bucks County and York County Disagree on Legality of Marriage According to the Pennsylvania Marriage Act, 10 Rutgers J.L. & Religion 18 (2009)


  1. ^ Cody Clark (Daily Herald). "You may now lick the bride: Canine clergyman helps household pets tie the knot". Pet Weds: Pet & Animal Nuptials. Retrieved 2009-06-15. 
  2. ^ Ctr. for Inquiry, Inc. v. Marion Circuit Court Clerk, 758 F.3d 869, 872 (7th Cir. 2014)
  3. ^