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.

US overview[edit]

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 the 1964 case of Universal Life Church Inc. vs. United States of America, the United States District Court for the Eastern District of California ruled that the Court would not "praise or condemn a religion, however excellent or fanatical or preposterous it may seem," as "to do so . . . would impinge on the guarantees of the First Amendment . . ."[1] All subsequent cases have ruled in favor of Universal Life Church as a legal and valid church establishment. The United States military chaplain's handbook lists ULC as a recognized church.[2]

The Internal Revenue Service (IRS) sued in the 1970s, arguing the ULC was not considered a religious group. The lawsuits were settled in 2000 with the church paying $1.5 million in back taxes.[3] The IRS has ruled in some years, but not in others, that the church was tax exempt, depending on whether the organization had filed its required annual statements in those years.[4] Most states recognize the church as a legal entity by extending recognition to its ministers.[5] Not all states recognize the ULC as a nonprofit organization; therefore, it is up to each minister to determine his or her legal standing. The ULC assists its ministers who experience problems with being recognized in their home state or country.[4]

In 2001, the state of Utah passed legislation banning ordinations via the internet. Subsequently, the ULC filed a lawsuit challenging the constitutionality of this legislation, and in 2002 a U.S. District Court ruled in favor of ULC on the grounds that online ordination is no different than ordination over the phone, by fax, or in person, various methods of ordination allowed under this legislation.[6]

ULC licenses also allow ministers to perform baptisms and funerals as well as the option to legally start their own organizations.[7][8]

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.

Another common criticism of ULC ordination is that some people, usually as a joke, submit ordination requests for their pets.[9] 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!"




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". (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)