ULC Court Cases: Rubino v. City of New York

Case Background

In the matter of the court case Anthony Rubino et al, vs. the City of New York, argued on June 8, 1984, a group of ministers ordained by the Universal Life Church petitioned the New York County Supreme Court to allow them the right to perform marriage rites. The petitioning ministers believed that the city had violated their rights to perform wedding ceremonies, a right given to them by their ULC ordination.

The Universal Life Church is a nonprofit organization that allows members of any and all religious denominations to become ordained as ministers through them. In doing so, they are given the legal right to perform marriage ceremonies, among other things.

Case Proceedings

This case saw Rev. Anthony Rubino and a group of other ULC ministers defend their right to perform marriages in New York.

The State of New York argued that the petitioners received no religious training of any kind from the ULC and did not follow a particular belief system in order to distinguish the organization that issued their ministers license as being part of any religion. They pointed to the fact that anyone could receive an ordination by sending a mail order to the founder of the Universal Life Church, Kirby J. Hensley, for a fee ranging from $2 to $20.

The petitioners argued that the refusal of the city to register them to perform marriage rites was against the law as it was a violation of the First and Fourteenth Amendments, which granted them the rights given to them by their church. According to the First Amendment, everyone has a right to be believe in whatever religious doctrine that they want. However, according to that same amendment, the law does not give them the absolute right to exercise those beliefs. The court declared “infringement of religious freedom” to not be the same as prohibiting acts done as religious duty.

Rulings And Outcomes

The New York County Supreme Court ruled that the act of marriage, its licensing, the way in which it is performed, and all marital obligations were of incredible importance to the state. It ruled that marriage rites were subject to the control of the state and that there were no First Amendment rights that dealt with the right to perform marriages. The court believed that there was a chance that the marriage between two persons could be ruled invalid in court if the marriage was administered by an ordained minister of the ULC.

Because of this, it was deemed understandable that the state would not want to risk the validity of someone’s marriage by allowing ministers ordained by the Universal Life Church to be registered to perform marriages. These ordained ministers were thus barred from performing marriage ceremonies in New York State. The belief that a marriage performed by an ordained minister of the ULC could have the chance of being annulled came from previous court cases in other states. At around the same time as this case was being argued, courts in both Virginia and North Carolina ruled, in separate cases, that ministers ordained by the Universal Life Church were not authorized to perform marriage rites in those states.

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

Read the court’s summary of this case here.