ULC Court Cases: Cramer v. Commonwealth of Virginia

Case Background

In 1974 a group of ministers ordained by the Universal Life Church had their rights to conduct marriage ceremonies taken away by the Circuit Court of Richmond, VA. This group of ministers, named under M.A. Cramer in the case, appealed the decision in the U.S. Supreme Court, asking it to rule that any minister who is able to provide documentation proving their ordination from any religious organization be allowed to conduct marriage ceremonies in the Commonwealth of Virginia.

Case Proceedings

The ruling of this court case made Virginia one of the three states in the US that does not accept the ULC's ordination.

The Supreme Court investigated the Universal Life Church in order to decide whether it was a legitimate religious organization. They came to the conclusion that the relationships between ministers of the ULC and the church’s administration were almost non-existent. The Supreme Court found that the ULC’s ordained ministers have few meetings in a congregation, if any at all. They found that those which did occur tended to be at a minister’s home or at restaurants, and that the topics discussed during the “worship services” often did not include religion.

The lower courts denied the right to officiate weddings to the appellants (Cramer and his fellow ministers) on the basis that ministers ordained to conduct such a rite should be full time ministers. The Supreme Court disagreed with the lower court’s finding, stating that there were plenty of ministers in Virginia that served their congregation as well as anyone while also being employed elsewhere.

The Supreme Court made sure to point out that the case in question had nothing to do with religious freedom. The need for a properly-certified minister was due to the legal nature of marriage (i.e. the fact that it is governed by the government). The Supreme Court declared that only someone that was responsible and had the integrity to manage a wedding contract should be allowed to conduct a wedding. The Supreme Court made sure to note that the state did not have any interest in where marriages were conducted or what type of ceremonies were used to conduct them. The court opined that ministers ordained by normal standards, such as, for example, through the Catholic Church, have undergone the kind of religious training that makes them inherently responsible and trustworthy to be certified as wedding officiants.

Upon looking into the Universal Life Church, the Supreme Court found that it did not fit the definition of any religious society, church or organization. They stressed that this had nothing to do with the case, however, stating that Cramer and the other appellants were allowed to belong to any group that they wished, and to call that group a church if they so desired to, a right given to them by law.

Rulings And Outcomes

The Supreme Court made the following rulings based on the case:

1. That the right to conduct marriage ceremonies was not limited to only full-time ministers.
2. That courts did not have to enforce a religious test upon the ministers in order to give them the power to perform wedding ceremonies.
3. That individuals wishing to perform weddings must be certified according to the state’s marriage laws.
4. That individuals who simply asked to become ordained and are granted their request were not ordained in a responsible way, and therefore are not abiding by marriage laws.

The US Supreme Court upheld the decision made by the lower courts, stating that obtaining a minister’s license should not be as easy as simply asking for one. They added that ministers certified to perform marriages should have some kind of training for the act, and that the license to wed should be earned, no matter where that person is ordained. Therefore, it was decided that it was against the law to perform marriage rites without being ordained by a recognized church in the Commonwealth of Virginia.

Case outcome: ULC ministers were/are no longer legally allowed to perform wedding ceremonies in Virginia

Read the court’s summary of this case here.