Adventists in American Courts—State v. Baldwin, Iowa Supreme Court, 1881
Seventh-day Adventists in the United States are no strangers to the courts. Whether as individuals or as formal church entities, they have sued each other, sued individuals and entities outside their communities, and have been sued by a variety of people and organizations, going back at least 130 years.
The first legal opinion that can be found on Westlaw and LexisNexis, two leading comprehensive legal databases, is State v. Baldwin, 10 N.W. 645 (Iowa 1881), a case decided by the Supreme Court of Iowa on December 8, 1881.
State v. Baldwin commenced when the trustees of the “Union Meeting-House of the Methodist Church” in Lick Creek Township, Iowa, filed a complaint in the state’s Van Buren (County) circuit court on February 24, 1879, alleging that Seventh-day Adventist leaders W. A. Carter, Josiah Saddler, E. J. Waggoner, Ira J. Hankins, and others had broken into and damaged the Union Meeting-House. The Methodist Church trustees requested the court to issue a preliminary injunction preventing Adventists from entering their church building.
It took the Van Buren circuit court ten months to issue its decision on this matter. When it did in December 1879, the court ruled that the Adventists may not break into or damage the Methodist church building. At the same time, the court held: “it is the duty of the said trustees to admit the defendants . . . to the use of said church, for religious service, when the Protestant Methodists are not using said church for said services, and when there is no other applicant for such purpose. The said trustees are hereby required and commanded to so admit defendants upon proper application.” In other words, the Methodists were required to give permission.
The reason for such a mandate? It was the Methodist church’s articles of incorporation which contained the following provision: “It shall be the duty of the board of trustees to admit all evangelical ministers of other churches at any time the Methodists are not using the house themselves.” Because the Methodist church itself had made available its own building to all other evangelical ministers when it was not using the building, the court said the trustees of the church could not discriminate.
After the Van Buren circuit court issued the order in favor of the Adventists, Josiah Saddler filed an application on Friday, January 2, 1880, for the use of the Methodist church building the next day. Thomas Baldwin, president of the Methodist church board of trustees, summarily refused the request. Saddler then asked Baldwin to call a church board of trustees meeting to consider the request, which Baldwin also refused.
Saddler then took the matter to the Van Buren court, which resulted in the court’s December order to be formally served on the Methodist church trustees. This compelled Baldwin to give public notice of a churchwide meeting to be held on February 14, 1880. Saddler and Carter attended the meeting on behalf of the Adventists, with a specific request to use the building on February 28, but waited outside the building while the church voted. The church resolved to refuse the Adventists’ request for these three reasons, which the trustees formally adopted:
(1) “[The Adventists] have caused strife, contention, and hard feelings in our neighborhood”;
(2) “They did break open and abuse said house, and failed to make good the damages done”;
(3) “We do not acknowledge as orthodox a people who deny the immortality of the human soul, and who violate and ignore the Christian Sabbath; who in theory deny the resurrection from the dead.”
The Adventists were insistent on having the Van Buren court’s order enforced. Thus, in April 1880, they filed an “information for contempt” against the Methodist church trustees, which led the court to issue an order to show cause as to why the trustees should not be punished for contempt in refusing to obey the December 1879 order. The trustees presented themselves in court in response to the order. The court fined Baldwin ten dollars or imprisonment for three days. Each of the other trustees was fined one dollar. In addition, the trustees were charged the costs of the proceeding, amounting to $98.10.
The Methodists appealed the Van Buren circuit court’s decision to the Supreme Court of Iowa. The Supreme Court announced its decision in this case on December 8, 1881—rendering what appears to be the first-ever legal opinion on a matter involving Seventh-day Adventists: State v. Baldwin, 10 N.W. 645 (Iowa 1881). (It’s “State” versus Baldwin because Baldwin appealed the state court’s order and contempt finding.)
The issues before the Iowa Supreme Court in Baldwin were “extremely technical,” as counsel for the Methodists admitted. They centered on the Van Buren circuit court’s authority to force the Methodist trustees to allow the use of their church to the Adventists and on what authority the trustees had once the church body had resolved not to give permission to the Adventists. At this thorny intersection between the authority of the judiciary, laws governing articles of incorporation of non-profit organizations, and free exercise of religion, the Supreme Court deftly sidestepped the weightier issues and hinged its ruling on the technical, as courts have often done.
The Court, in an opinion written by Justice James G. Day, ruled that it was incumbent upon the trustees of the Methodist church, when faced with injunction and contempt orders from the Van Buren circuit court, to challenge the orders in the same court, if the trustees objected to the orders. The trustees had no authority to simply disobey the orders. The Supreme Court explained: “the order of the court, even if erroneous, was not void. The court had jurisdiction of the parties and of the subject-matter, and its adjudication cannot be disregarded with impunity. So long as it remains unreversed it must be obeyed.” If individual parties simply disregarded judicial orders, the Court opined, “[t]here would be an end of all subordination and social order . . . .” Thus, because the Court found “no illegality or error in the action of the [Van Buren circuit] court,” it “approved and confirmed” the lower court’s decision to enjoin the trustees and find them in contempt.
How the two parties handled the dispute in the aftermath of the Iowa Supreme Court’s decision is unknown. The Review and Herald does not report this episode or the Court’s decision; the Methodist church in Lick Creek Township (which belonged to the Free Methodist tradition) appears to have closed its doors some time thereafter. An account that seems to describe this story does appear in the “Progress of the Cause” (church news) section of the March 27, 1879 issue of the Review. Ira Hankins and E.J. Waggoner, two of the four Adventists named in the original lawsuit, reports of the Adventist work in Van Buren County, Iowa:
We held a series of meetings in a country place four miles from Douds. [Lick Creek sits about five miles from Douds.] About twenty began to keep the Sabbath. Opposition, the most bitter, did much to help the work. Regular Sabbath meetings were established, and a Sabbathschool was organized. Last Sabbath, March 15, we met with them again and enjoyed a precious season. All are firm, and two more families have united with them. The leading man in the Methodist church, a local preacher, has recently taken his stand on the Sabbath. The doors of the church are closed against them, and at present meetings are held in a private house. All seem to have a desire to learn the truth, and to walk in the increasing light. . . .
We held meetings at Cantril [23 miles south of Lick Creek], and the interest and attendance were good. Had the free use of the Methodist church, and our expenses all paid. Seven began to keep the Sabbath, and we hope for others who are almost persuaded.
Even if the first paragraph of this brief report describes the experience of a different Adventist group in Van Buren County, this account—at the very least—provides a view into the immediate backdrop of the conflict between Adventists and other Christians that reached all the way to the state’s highest court. Although Methodists in nearby Cantril continued to permit Adventists free use of their church, it is easy to see how Methodists in other nearby towns, such as in Lick Creek, would feel that Adventists “have caused strife, contention, and hard feelings in [their] neighborhood,” once some of their leading members began worshipping with the Adventists. If the first paragraph of the report in the Review does refer to the early stages of the conflict in State v. Baldwin, it helps explain why the Adventists (who included a former “leading man” of the Methodist church who until recently had preached to that church and understood well the church’s articles of incorporation) would feel emboldened to break into the Methodist church building.
State v. Baldwin may have been a public relations disaster for Adventists among Methodists in Van Buren County, Iowa, but it represented a significant victory. It showed a surprising degree of willingness on the part of the Adventists in Iowa to pursue a legal remedy in a matter in which the dispute centered on the application of the Methodist church’s internal laws. It is also surprising how the state court was willing to issue and maintain an injunction against the Methodists, particularly after the church body stated that it does not consider Adventists to be “orthodox” (which, presumably, would disqualify Adventist leaders from being “evangelical ministers,” one of the conditions of free use of the Methodist church). Courts today might agree narrowly with the Supreme Court’s affirmance of the lower court’s contempt finding, but it is hard to imagine a contemporary court “meddling” with intra-religious policy decisions and inter-denominational disputes such as what occurred in Baldwin, unless a clear violation of established constitutional and statutory rights occurred.
Since 1881, Adventists, individually and institutionally, have gone on to amass a remarkable record of success in American courts. Cases and judicial opinions involving Adventists have played an important role in shaping American jurisprudence on the First Amendment and the reach and limits of the judiciary in matters involving religious institutions and their practices—the very issues present in State v. Baldwin. In this series we will take a look at some of the more interesting, surprising, and significant cases involving Adventists in American courts. If you have any case suggestions, please share in the comment section.
—Julius J. Nam works as a judicial clerk in the Central District of California of the U.S. District Courts. He is also an associate professor of religion at Loma Linda University School of Religion. He holds a Ph.D. in Church History/Adventist Studies from Andrews University and a J.D. from UCLA School of Law. In 2011-12, he served as editor-in-chief of UCLA Law Review.
