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

August 22nd, 2012

Case Background

ULC Court Cases: Ravenal v. Ravenal

The outcome of this court case prevented ULC ministers from performing marriage ceremonies in New York County until it was later overturned.

In the case of Ravenal v. Ravenal, Richard S. Ravenal asked the Supreme Court of New York County for an annulment of his marriage to Cathy Linton Ravenal on the grounds that the individual who solemnized the marriage was not authorized to do so. Cathy Linton Ravenal appeared in court but did not defend the marriage.

According to Richard Ravenal, the individual who solemnized the marriage was a guitarist and folk singer that was ordained as a minister by the Universal Life Church, a fact which both Cathy Linton Ravenal and Richard Ravenal were aware of. A marriage license was obtained from the city clerk of New York City. The city clerk would have challenged the validity of the marriage had it occurred in the city, due to the fact that the person who solemnized the marriage had not registered his name or address in the city clerk’s office, which was required by the Domestic Relations Law.

The Domestic Relations Law states that a marriage is only valid if it has been solemnized by a minister or clergyman of any religion, by a mayor or city clerk, or by a justice or judge. The marriage would also be considered valid if a written contract was signed by both parties along with two witnesses. The location and date must also be included in addition to the fact that the contract must be acknowledged by a judge of a court within the same state.

Case Proceedings

According to the Religious Corporations Law, both traditional churches and denominations, as well as unincorporated churches and any groups that are formed for religious practice, are accepted. An “unincorporated church” is defined as a group or congregation of people that meet for religious worship or practice, but that has not been incorporated for that purpose. The terms “clergymen” and “minister” were defined as anyone that has been given the authority to direct the spiritual or religious affairs of a church or synagogue.

The religious freedom guaranteed to every American citizen by the constitution means that everyone has the right to be married by the minister of their chosen faith. This ruling was enforced in previous court cases such as in the case of O’Neill v. Hubbard. The individual who solemnized the marriage of the Ravenals had received ordination from the ULC, which granted him the ability to solemnize marriages.

The Universal Life Church was incorporated in 1962 in Modesto, California. According to a letter from the office of the California Secretary of State, introduced as evidence to the Supreme Court of New York County, they did not know whether or not the ULC was a religious denomination or not. In fact, the New York Secretary of State informed the attorneys of Richard Ravenal that there was no record of the ULC and that it had no sites in the city of New York, where the marriage took place.

According to the Universal Life Church legal team, there were over 1,000,000 ministers in its online ministry at the time, all of whom were given the right to legally solemnize marriage ceremonies. Anyone who wished to become a minister with the Church could do so.

Rulings And Outcomes

The Supreme Court ruled that the Universal Life Church was not an ecclesiastical body of denomination and that therefore the person who solemnized the marriage had no authority to do so. Because he did not have a congregation or meet with a congregation in a place of worship, that person’s authority to perform marriages came solely from a certificate supplied by the Church. The Supreme Court annulled the marriage of Richard Ravenal and Cathy Linton Ravenal on November 20, 1972.

Outcome: Universal Life Church ministers became unable to perform marriage ceremonies in New York County


  1. Rev Richard Leroy Chambers says:

    I just became ordain in July 25 2012. I live in Erie county New York, and my church is in Erie county. With this ruling am I legal to perform weddings in New York? This story is confusing. I did not became ordain to be fraudulent minister. I am with a church as a vice pres. But there is no full time minister. we prefer sub pastors to hear different ways of the Bible.

  2. danimal says:

    I’m confused too.

    What the heck is New York County? Where is that?

    Why is it that ULC doesn’t sue the state of ny for not recognizing them when other states clearly do?

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