ULC Court Cases: O’Neill v. O’Neill

Case Background

One of many court cases of its kind, O'Neill v. O'Neill established that the weddings performed in Bucks County, Pennsylvania should be legally recognized.

This case concerned Jason B. O’Neill and Jennifer R. O’Neill as they submitted to the Court of Common Please of Bucks County, PA for a decision regarding the validity of their marriage. They had been married by a minister who was ordained by the Universal Life Church. The court had to decide whether a minister ordained by the Universal Life Church was a valid minister according to the Pennsylvania Marriage Act.

The O’Neills were both raised on the basis of several religions and were taught to be open-minded, spiritual individuals. As such, they wished that their wedding would retain a religious aspect, but to not be dominated by a single religious tradition. Their solution was to have Jason O’Neill’s uncle, Robert A. Norman, a ULC-ordained minister, perform the marriage ceremony.

The ULC allows anyone of any background or religious belief to become ordained online, and thus be a minister who can perform legally-recognized weddings. This online church believes that all people have the right to practice their unique beliefs as long as they are within the law. They have ordained over 20 million members since the original branch was founded in 1959. Prior to this litigation, the Universal Life Church had been involved in or the subject of many court cases regarding the legality of its ordination or the right of its ministers to perform weddings.

Case Proceedings

Mr. Norman testified before the court that he believed wholeheartedly in the principles and teachings of the Universal Life Church, and that he lives his life accordingly. The marriage took place on September 3, 2005 in Bucks County. On September 12, 2005 the couple’s certificate of marriage was filed at Buck County’s Clerk of the Orphan’s Court.

A few years later, on September 7 2007, the York County Court of Common Pleas invalidated a marriage conducted by a ULC minister in the case of Heryer v. Hollerbush. The court stated that a minister needed an actual congregation and a place of worship to be considered a minister in order to abide by marriage law.

The decision led to confusion among couples married by ULC-ordained ministers. The O’Neills became worried that this meant their marriage was invalid. Not only would this cause emotional distress, Kevin O’Neill testified, but it could also lead to legal problems concerning their joint tax returns, healthcare and life insurance benefits and more. They sought validation of their marriage in court for these reasons

Pennsylvania’s marriage law stated that a written contract and a marriage certificate signed by the individual who was authorized to perform the marriage were what was needed to make a marriage legal. That same act also stated that a third-party clergy or officiant and the couple’s religious society or organization were all legally able to solemnize the marriage. The couple themselves could do it as well, as long as there were witnesses at hand. The court pointed out that the law provided several ways to be solemnized so that couples could have their marriages performed in the way they wished to be married. The main issue at hand was whether or not Mr. Norman belonged to any of the groups allowed to solemnize a marriage or, more specifically, whether he was a minister of a regularly-established church. (Anyone who has read through ULC court cases knows that Universal Life Church ministers sometimes face doubt from government officials about whether or not they are members of regularly-established churches)

Rulings And Outcomes

The court decided that the word “church” was not restricted to a physical location. Had the law meant for it to mean an actual physical place of worship, it would have been more specific. This led to the court ruling that the ULC was a legitimate religious organization according to the Marriage Act.

On December 31 2008, the court ruled that Mr. Norman had not only properly performed the marriage of the O’Neills, but that he was in fact a minister of a legitimate religious organization, making the marriage between the O’Neills a valid one.

Case outcome: weddings performed by Universal Life Church ministers are legally valid in Bucks County, Pennsylvania

Read the court’s summary of this case here.