Universal Life Church Case Law
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ULC Court Cases: Lynch v. Universal Life Church

August 23rd, 2012

Case Background

ULC Court Cases: Lynch v. Universal Life Church

The Ninth Circuit Court of Appeals found that the ULC was not guilty of committing fraud in this case.

In the case of Lynch v. Universal Life Church, Sandra Lynch initially took the Church to court for allegedly committing fraud. She claimed that the ULC of Modesto, CA guaranteed that their ordained ministers would be able to perform valid marriage ceremonies in the state of North Carolina. The verdict found that the Church was liable for fraud. Lynch was awarded $10,000 in compensation on the basis that she suffered emotionally due to the fact that her marriage was invalid. She was also awarded $150,000 in punitive damages. The Universal Life Church legal team appealed the decision to the Fourth Circuit Court of Appeals.

The ULC ordains ministers without requiring any special training in the belief that anyone of any religious background or creed should be able to become ordained. They do not require any fees although they do welcome donations and charge for the ministerial documentation and other ministerial products they sell. Ordination is received through a mail order.

Sandra Lynch’s father, Chester Wilson, responded to an advertisement by the church and received his ordination on the basis that he would be able to help people as a Christian. He sent in an application as well as a small donation, and in return received a ministerial certificate as well as a document stating that he was now able to perform the services of a minister, including solemnizing marriages. The document also suggested that he check to see if he needed to be licensed by the city, county or state. He followed the suggestion and checked with the county clerk of the county where the Lynch wedding was to be performed. He was informed that he could officiate marriage ceremonies in the state of North Carolina.

Chester Wilson married Sandra Lynch to James Lynch on October 28, 1973. They separated in 1977. In April of 1978, James Lynch’s lawyer sent Sandra Lynch a request that they be divorced in the Dominican Republic in order to save money. She refused. James Lynch then informed her that his lawyer believed their marriage to be invalid. James Lynch then married his girlfriend without obtaining a divorce from Sandra Lynch. In subsequent court cases regarding the matter, James Lynch was convicted of bigamy. However, the North Carolina Supreme Court reversed the decision on the grounds that their marriage was indeed invalid due to the fact that Chester Wilson had not been authorized under State law to perform the marriage.

Case Proceedings

Sandra Lynch took the ULC to court for fraud in August 1981. However, by the facts of the previous case concerning James Lynch’s bigamy trial, she would have known of the fraud before August of 1971. The statute of limitations for fraud is three years. She knew at the time of the marriage that her father, Chester Wilson, was an ordained minister of the Universal Life Church. She also knew that he had no formal training to become a minister nor had he obtained any training after becoming one. She had also testified around June of 1978 that James Lynch had told her their marriage was not valid. Even though she did not believe him, she knew of all the facts that resulted in the marriage being voided by the North Carolina Supreme Court.

Sandra Lynch argued that the statute of limitations should be extended from the point that she gained knowledge of the law governing fraud and not from the point that she learned the facts that constituted the fraud. The court rejected her argument.

Rulings And Outcomes

The Fourth Circuit Court of Appeals ruled in the favor of the Universal Life Church due to the fact that the statute of limitations had passed. They overturned the decision made by the District Court for the Middle District of North Carolina.

Outcome: the Universal Life Church was not convicted of fraudulently promising one of its ministers that it could perform wedding ceremonies with its ordination, thus affirming that ULC ministers are allowed to officiate weddings in North Carolina


  1. Reverend Joseph Cormier says:

    People try to make money off anyone these days; including GOD!

  2. Rev Cr Doc Fazzio Ph D says:

    I have been taunted by various individuals doubting the on line ordination of the ULC like accredation for the University of Phoenix.I say hats off to the ULC for standing up for our constitutional rights..
    Rev Cr Doc Fazzio Ph D ULC Minister proudly stated

  3. Kelly H. - Farmin'country, Michian says:

    In reading the above article, I am misunderstanding or possibly not at all understanding. If the father of the bride needed a city or county permit of some kind, how can it then be “… thus affirming that ULC ministers are allowed to officiate weddings in North Carolina.” yet the marriage was fraudulent?

    • Doug says:

      The ULC gives specific instructions telling anyone officiating at a wedding as a ULC minister. To register their credentials with the county they preside in. If an Ordained minister of any faith fails to Register with in the county they live. Any marriage ceremony performed would be invalid, and a fraud.All Christian Religious groups of any kind are told this. It is the law.

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