The Temple Lot Case (formally Reorganized Church of Jesus Christ of Latter Day Saints v. Church of Christ) was a United States legal case that addressed legal ownership of the Temple Lot, a significant parcel of land in the Latter Day Saint movement. In the case, the Reorganized Church of Jesus Christ of Latter Day Saints (RLDS Church) claimed legal title of the land and asked the court to order the Church of Christ (Temple Lot) 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 Temple Lot is a small parcel of land in Independence, Missouri. In the early 1830s, the lot was designated by Joseph Smith, Jr. as the site for a proposed temple for the prophesied city of New Jerusalem. In 1831, Latter Day Saint Bishop Edward Partridge purchased the Temple Lot from Jones H. Flournoy and Clara Flournoy on behalf of Smith's Latter Day Saint church. Partridge held the property in trust for the church.
The proposed temple was never built on the site and the Latter Day Saints were ultimately driven out of Missouri. After this, legal title to the property became a matter of dispute, with three separate theories of who inherited legal title to the property. In any case, the Church of Christ (Temple Lot) (the "Hedrickites") ultimately found themselves in possession of the Temple Lot. The Hedrickites constructed a small church building on a corner of the property, but no building was constructed on the designated site for the temple.
In 1891, the RLDS Church filed suit in the United States District Court for the Western District of Missouri claiming equitable title to the Temple Lot, which was under the control by the Temple Lot church. After Joseph Smith's death, the Latter Day Saint movement had splintered into a number of separate churches; Smith's son Joseph Smith III was the president of the RLDS Church and claimed that the RLDS Church was the rightful successor to the original Latter Day Saint church. 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 Church of Jesus Christ of Latter-day Saints (LDS Church) also participated in the case, providing funds and legal advice to the Hedrickites.
In 1894, the trial court held 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. It 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.
The Church of Christ (Temple Lot) appealed the trial court's decision to the United States Court of Appeals for the Eighth Circuit. 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 before an en banc panel of the Appeals Court, but the motion was dismissed. The RLDS Church then sought to appeal the decision to the United States Supreme Court, but that court denied certiorari, which brought the case to a close.
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, 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.
- S. Patrick Baggette, II, ""The Temple Lot Case: Fraud in God's Vinyard", John Whitmer Historical Association Journal 23 (2003): 121–136.
- Reorganized Church of Jesus Christ of Latter Day Saints v. Church of Christ, 60 F. 937 (C.C.W.D. Mo. 1894).
- Ron Romig, "The Temple Lot Suit After 100 Years", John Whitmer HIstorical Association Journal 12 (1992): 3–15.
- Church of Christ in Missouri v. Reorganized Church of Jesus Christ of Latter Day Saints, 70 F. 179 (8th Cir. 1895).
- Reorganized Church of Jesus Christ of Latter Day Saints v. Church of Christ, 71 F. 250 (8th Cir. 1895).
- Reorganized Church of Jesus Christ of Latter Day Saints v. Church of Christ, 163 U.S. 681 (1896).
- The Temple Lot Case [trial and appeal transcripts] (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)