Church Titles in Pennsylvania

Generally

• 10 P.S. § 81 (Church property to be subject to control of officers or authorities thereof; validation of certain charters)

Unincorporated Nonprofit Associations

• 15 Pa.C.S. 9114 (Entity status)
• 15 Pa.C.S. 9115 (Ownership and transfer of property)
• 15 Pa.C.S. 9136 (Subordination of chapter to canon law)

Nonprofit Corporations

• 15 Pa.C.S. 5501 (Corporate capacity)
• 15 Pa.C.S. 5107 (Subordination of subpart to canon law)
• 15 Pa.C.S. 5546 (Purchase, sale, mortgage and lease of real property)
• 15 Pa.C.S. 5547 (Authority to take and hold trust property)

Specific Denominations

Episcopal

• Calvary Episcopal Church, Pittsburgh v. Duncan, No. 293 C.D. 2010, 2011 WL 10841592 (Pa. Commw. Ct. Feb. 2, 2011) (also discusses property rights where congregation withdrew from national Episcopal organization and joined an Anglican organization)

Presbyterian

• Peters Creek United Presbyterian Church v. Washington Presbytery of Pennsylvania, 90 A.3d 95 (Pa. Commw. Ct. 2014) (non-profit corporation) (majority voted to disaffiliate from one national church and join another national church)
  • Footnote 6 for overview of hierarchy and organization of the "Presbyterian Church (U.S.A.)"

Roman Catholic

• St. Peter's Roman Cath. Par. v. Urb. Redevelopment Auth. of Pittsburgh, 394 Pa. 194, 146 A.2d 724 (1958) (congregation could not assert rights because property is owned by the Church acting through Bishop who agreed to the disposition)
• St. Matthew's Slovak Roman Cath. Congregation v. Most Reverend Wuerl, 106 F. App'x 761 (3d Cir. 2004) (members of dissolved ("suppressed") parish could not assert rights of parish which no longer existed)
• Croatian Roman Cath. Congregation of Holy Trinity Church, Ambridge, Beaver Cnty., Pa. By & Through Cvitkovic v. Wuerl, 447 Pa. Super. 208, 668 A.2d 1151 (1995) (members of dissolved ("suppressed") parishes lacked standing to pursue claims and the suppression itself is a matter of church canon law that could not be reviewed in a civil court)