10

See, e.g., First Baptist Church of Hope Hull v. Owens, 474 So.2d 638 (Ala. 1985); Foster v. St. John's Baptist Church, 406 So.2d 389 (Ala. 1981); Putman v. Vath, 340 So.2d 26 (Ala. 1976); In re Galilee Baptist Church, 186 So.2d 102 (Ala. 1966); Williams v. Cupp, 597 S.W.2d 855 (Ark. App. 1980); United Methodist Church v. White, 571 A.2d 790 (D.C. App. 1990); Hemphill v. Zion Hope Primitive Baptist Church, 447 So.2d 976 (Fla. App. 1984); Covington v. Bowers, 442 So.2d 1068 (Fla. App. 1983); Epperson v. Myers, 58 So.2d 150 (Fla. 1952); Sanders v. Edwards, 34 S.E.2d 167 (Ga. 1945); Stony Island Church of Christ v. Stephens, 369 N.E.2d 1313 (Ill. App. 1977); Hatfield v. De Long, 59 N.E. 483 (Ind. 1901) (salary of expelled minister held not to be a property right); State ex rel. Hatfield v. Cummins, 85 N.E.2d 359 (Ind. 1908) (church membership is purely ecclesiastical, not a property or civil right); Ramsey v. Ahicks, 91 N.E. 344 (Ind. 1910) (church membership not a civil or valuable right); Sale v. First Regular Baptist Church, 17 N.W. 143 (Iowa 1883) (expulsion from religious corporation affects no property interest or civil right); Le Blanc v. Davis, 432 So.2d 239 (La. 1983); Quinn v. First Evangelical Baptist Church, 135 So.2d 753 (La. App. 1931); Sance v. Monroe, 39 So.2d 174 (La. App. 1949); Graffam v. Wray, 437 A.2d 627 (Me. 1981); Beulah Missionary Baptist Church v. Spann, 346 N.W.2d 911 (Mich. App. 1984); Vincent v. Raglin, 318 N.W.2d 629 (Mich. App. 1982); Blauert v. Schupmann, 63 N.W.2d 578 (Minn. 1954); Dees v. Moss Point Baptist Church, 17 So. 1 (Miss. 1895) (excommunication from church involves no property rights); Stamps v. Kirkendoll, 689 S.W.2d 111 (Mo. App. 1985); State ex rel. Hynes v. Holy Roman Apostolic Catholic Church, 170 S.W. 386 (Mo. 1914) (excommunicated priest has no property right in his profession or salary); Pounder v. Ashe, 63 N.W. 847 (Nebr. 1895) (church membership not a property right, nor is right to officiate as minister or resulting right to salary); Chavis v. Rowe, 459 A.2d 674 (N.J. 1983) (court dismissed lawsuit by defrocked church officer despite claim that his civil, contract, and property rights were violated); Protestant Episcopal Church v. Graves, 391 A.2d 563 (N.J. Super. 1978), aff'd 417 A.2d 19 (1979); Waller v. Howell, 45 N.Y.S. 790 (1897) (church membership involves no civil right); Nance v. Busby, 18 S.W. 874 (Tenn. 1892) (expulsion from church affects no pecuniary or civil right); Waters v. Hargest, 593 S.W.2d 364 (Tex. App. 1979); Bennett v. Belton, 436 S.W.2d 161 (Tex. App. 1968).