ULC Court Cases: State of North Carolina v. Lynch

Case Background

This case saw the legal status of a wedding performed by a ULC minister called into question by the Supreme Court of North Carolina.

Summary: The Superior Court of North Carolina convicted James Roberts Lynch of bigamy. He appealed the decision to the Court of Appeals, but the decision stood. Lynch then took his appeal to the North Carolina Supreme Court. The decision was reversed when it was found that his first marriage was solemnized by someone who had bought minister credentials for a sum of $10 through a mail order. Because this marriage was invalidated, the ruling of bigamy was overturned.

Witnesses who testified against Lynch included his alleged first wife and the two wedding officiants who performed their wedding. Evidence of the crime of bigamy included a certificate of ordination (or minister’s license), which one of the wedding officiants obtained from the Universal Life Church, a marriage certificate as well as the license and marriage certificate from the second marriage.

James Roberts Lynch was married to his first wife, Sandra Lynch on October 28, 1973. Sandra Lynch’s father, Chester A. Wilson, was the wedding officiant. He was a Roman Catholic who had obtained his minister credentials from the Universal Life Church. Two of her friends acted as official witnesses by signing the marriage license. According to Sandra Lynch, no divorce proceedings ever occurred between her and James Robert Lynch, making her believe his second marriage was against the law.

Wilson obtained the ordination from the ULC after becoming a born again Christian. He did not officiate over any congregation and continued to attend a Roman Catholic Church. The ULC allows anyone of any background to become ordained to be a minister, even a practicing Catholic like Rev. Wilson. The marriage between James Robert Lynch and Sandra Lynch was the only marriage Wilson ever solemnized.

On July 8 1978, Clayton H. Persons performed the marriage of James Roberts Lynch and Mary Alice Bovender. Persons was an ordained minister of the Moravian Church. Persons was aware of the previous marriage, but believed that the marriage was invalid due to the fact that Wilson was not a legitimately ordained minister. Persons checked with the doctrine of both the Moravian Church and the Roman Catholic Church before proceeding with the wedding.

Case Proceedings

Lynch testified that he did not know Wilson was a born again Christian and had never seen his marriage credentials. He did know, however, that Wilson had obtained something of the sort through a mail order. After speaking with Persons as well as his attorney, Lynch believed his first marriage was invalid. During the cross examination of Lynch, the state produced a letter sent to Sandra Lynch on the behalf of James Roberts Lynch asking her for a divorce that was to be obtained in the Dominican Republic in order to avoid the fees associated with divorce proceedings in North Carolina.

In order for a marriage to be a lawful one under North Carolina marriage laws, the officiant must be either a minister ordained by any religious denomination, a minister that was authorized by his church to perform a wedding, or a magistrate. The Supreme Court declared that in order to determine whether James Roberts Lynch’s first marriage was lawful, they would have to determine whether Chester A. Wilson was a legitimate wedding officiant under state law. The state was required to establish beyond reasonable doubt that Wilson was a legitimate minister of the church under North Carolina marriage laws in order to find James Roberts Lynch guilty of bigamy.

Rulings And Outcomes

On December 2, 1980, the Supreme Court ruled that purchasing a minister’s license through the mail is not recognized by the state for the purposes of a bigamy prosecution. The Supreme Court reversed the previous ruling, stating that the state failed to prove that the prior marriage was legitimate.

Outcome: the ability of Universal Life Church ministers to perform a wedding in North Carolina became invalidated.

(Please note that this decision would later be reversed in Fulton v. Vickery in 1985)

Read the court’s summary of this case here.