St. James Newport Beach Files SCOTUS Petition

The link to a .pdf of the brief may be found here:
http://steadfastinfaith.org/content/st-james-ussc-petition
The Curmudgeon has lots more.

Let’s consider the flip side of what could happen if this petition works
Suppose that all forms of discrimination against gender/orientation discrimination were banned.  Would the government be “favoring” (ie allowing certain groups to set aside statutes that normally apply to everybody else if they didn’t force religious groups to perform weddings for “everybody”? 

Not that I don’t want those separating to keep their property, but there is a case to be made that allowing canon law (even if misrepresented and/or unjust) to run its course is the least meddlesome thing the government can do.  Overturning canon law (even if misrepresented and/or unjust) and making it subject to exact letter of secular law can set a bad precedent down the road.

I could be wrong.  Maybe I’m just paranoid.  But we have to be careful when we ask the government to take a strong position in church affairs.

As I understand it, the petition does not speak to Canon law but to property and trust law.

#2 If I understand your point, the better analogy woulf be if a law allowed self-described ‘hierarchical’ churches to refuse to perform same-sex marriages, but required other types of churches to do so. Or vive versa.

Re [3]: Paula, as I understand, the petition claims that within the church, property/trust law should override canon law, as the California SC ruled in favor of TEC on the basis of the interpretation of canon law.

[4]: Toral1, perhaps there are better analogies than mine, but *if* the constitutional principle that emerges is that secular law must apply uniformly to religious bodies regardless of their internal structure as if they were ordinary organizations, I would be afraid.  Currently, I believe that religious bodies may perform or refrain from performing any (legal) marriage.  If there were a strong “antidiscrimination” law, a principle of religious bodies being uniformly under secular law like any other organization could become problematic.  Despite its drawbacks, the California SC ruling at least has the merit of staying out of how religious bodies organize their internal affairs.  This is separation of church and state.  The (admittedly worst case) scenario I suggest has the effect of putting church under state.

But canon law doesn’t necessarily always trump secular law.  Suppose canon law allowed a man to have multiple wives.  The courts would not recognize any additional marriages after the first one.

I agree, canon law cannot be made supreme, either.  But my main concern is that we need to make sure we’re not asking to be treated like ordinary secular organizations, or else we could open ourselves up to the same regulations they fall under.  California (I think it was) has ruled that Catholic Charities falls under nondiscriminatory hiring laws (e.g. religion, sexual orientation) because they serve a primarily secular rather than religious purpose.  This is an example (granted, in CA) that we need to maintain and jealously guard a distinction between the two kinds of organizations in our legal system.

Rob Kirby, I think you are standing the question on its head. Long before there was ever an Episcopal Church, hierarchical or no, there was a Statute of Frauds that required all trusts to be expressed in a writing signed by the owner of the property being made subject to the trust.

Then along comes a church (ECUSA, PCA, UMC—- you name it) that claims to be “hierarchical”, and all of a sudden the Statute of Frauds doesn’t apply any more? The governing body of the Church gets to declare it has a trust interest in all parish property in every single State, without having to bother with laws in each of the 50 individual States?  (And even if a given State passed a law allowing ECUSA, PCA and UMC to do so, that statute would not create a problem with favoring some religions over others?)

The situation you hypothesize—- with a general non-discrimination law—- is altogether different.  Since no church can perform a marriage recognized by the State unless the clergy performing it agrees to act as an agent of the State, then the solution would be for the Church to say it will no longer have its clergy act as agents for the State. People can still get married by the county clerk without discrimination. And those who want to have an additional ceremony in their church are just exercising their right of free exercise of their religion.

But in the case of trusts in parish property, the counterpart is not at all true.  Under the Dennis Canon as construed by the California Supreme Court, no Episcopal parish has the ability to “opt out” of the Canon, and say that the Statute of Frauds has to govern their property rights.  No, because they are in a particular type of Church, the California Supreme Court says that they cannot even choose to join it without signing away their right to their own property forever.  This is “reverse discrimination” in spades—- and it is available only to churches that self-declare themselves as “hierarchical”.  If that isn’t establishment of a State-favored “religion”, then I guess I will just have to eat my Prayer Book.

Just dropping by for posts.
Intercessor

But Chancellor, 8, you’re in effect asserting that (i) an exception to the Statute of Frauds may not be created by another statute, and (ii) a congregation may join an organization with binding rules and then may simply opt-out of whatever rules the congregation decides (30 years after the fact) that it does not like.

This petition is doomed to fail for at least two reasons.  First, agreeing with what it says would require the Supreme Court to find deference unconstitutional.  Second, it asserts that differences between states are a constitutional bug when the Supreme Court has been crystal clear that such differences are a feature.

On one side, you have TEC asking the courts to overturn existing property deeds on the basis of (their understanding of) canon law.  I’m uncomfortable with that, especially since the parishes (and in DSJ, dioceses) don’t have the same self-understanding as 815 as the nature of property ownership.

It is a matter of simple fact that some churches are purely congregational (e.g. baptists) and that there is no claim of the overarching church on the local property.
It is also the case that some churches (e.g. RCC and UMC to a lesser extent) have a well-developed sense of the organization owning the church property and that by contributing to the building fund, your community does not own the property outright.  In TEC this has been somewhat nebulous.  Does the Dennis Canon simply make explicit what is implicit in TEC already?  Does it mark a point of departure in canon law, moving from dioceses as the locus of ownership to 815?  Is a secular court competent to judge?

So, on the other side, the Anglicans are asking the court to overturn the national church’s (claimed understanding of) canon law.  I am also uncomfortable with secular courts deciding points of canon law for the church. The California ruling seems to me to be viewing the the canon law as “opaque” and not attempting to override it.  It may be an overreaction or irrational fear, but I fear the abstract principle of secular law trumping canon law in these disputes could have unintended consequences down the road.

In DioNWT, there is another interesting case where the bishop EXPLICITLY deeded the property from the diocese to the particular parish so that they could do some construction work without diocesan debt liability.  It was never deeded back.  Along comes VGR, and the rest is very interesting…

No, DavidH, I am saying that an exception to the Statute of Frauds, which is a statute of general application in all fifty States, may not be created (in a given State) by another statute which says that only certain churches do not come within its application. Such an exception establishes those very churches as State-favored churches in violation of the First Amendment.

The rules of “the congregation” which the parish in question chooses to “join” may still not bypass the ordinary statutory provisions to which all entities are subject.  To take an extreme example: suppose the canons of a particular self-proclaimed “hierarchical” church provided that “all persons except DavidH may be members of this Church.”  Would you defend the right of that Church to enact such a canon?  Also, for the sake of argument, let’s say that the church in question passes the canon at DavidH’s birth, but does not get around to announcing it to its parishes until DavidH is 21.  Same result, in your view?

“Deference” is the exact opposite of “neutral principles”.  You cannot be said to apply “neutral principles” if you defer to hierarchical ones. So if you profess to follow neutral principles, then yes—- “deference” to a hierarchical church is “unconstitutional”—or more correctly, it is not “neutral”.  You can either choose to “defer” under Watson v. Jones, or you can apply “neutral principles” under Jones v. Wolf, but you cannot adopt “neutral principles” which require that you defer to “hierarchical” churches.

Chancellor, 12, you’ve helped show one of the cardinal weaknesses in the Petition by arguing (like Justice Kennard) that California claims to apply neutral principles but actually applies deference.  Under current Supreme Court case law, it is indisputable that California can apply deference.  If that is not constitutionally problematic, then it cannot possibly be constitutionally problematic for California to apply deference in neutral principles drag.  (I figured I should use wording appropriate for California.)

Re the statute of frauds, all that the California statute at issue says is that where a church is hierarchical, it can control the property via a trust canon.  The predicate (which the St James folks dispute) is that TEC is hierarchical.  Deference to a hierarchical church’s rules is perfectly constitutional.  (And my point above was that California is obviously able to modify its own statutory rules, like the statute of frauds.)

As to your hypo in paragraph 2 (which is not analogous because there is no statutory provision providing that a church may not exclude me), yes, I think a church (like any association) has the right to choose who can be a member.  If that excludes me, so be it.

Loads of lawyer speak going on here….I’ll just sit back and listen and pretend to know what is being said.

DavidH, with all due respect, you are not addressing my arguments. I am not sure, therefore, that we can have any further meaningful exchanges on these points. 

I contend that current law allows either deference to a (genuine) hierarchy, or the application of neutral principles without regard to a church’s structure, and you respond that “if California can constitutionally apply deference, then it can apply deference in neutral principles drag.” But “deference” is by definition not “neutral principles”; the latter is an alternative to the former. Your characterization conflates the two approaches in a way that Jones v. Wolf neither supports, nor even contemplates. To have an “alternative” approach means to follow an approach that is different from any other approach, and not simply to dress the same old approach up in fashionable garb and claim it is a different approach.

“Deference to a hierarchical church’s principles is perfectly constitutional”—- yes, but not if you claim to be applying “neutral principles”.  Don’t you see? You cannot be “neutral” and “deferential” at the same time.  If you are Watson, you cannot at the same time be Jones. Likewise, California has no ability to pass a statute saying: “all persons in this State except the Episcopal Church have to observe the Statute of Frauds when creating a trust, because California regards the Episcopal Church as something special.”  If you are unable squarely to address this point, then you and I will never meet on common ground.

My hypothetical was meant to assume current civil rights laws, pursuant to which you could not be excluded from membership in a church just by virtue of your name, skin color, hair color, or other irrelevancy. And we are not talking about the right of a church to determine whether or not you meet its genuine qualifications to be a member, but to legislate a priori at your birth that you can never be a member, solely (say) by reason of your mother’s maiden name.

But I suspect that others at this blog will have tired of tracking our points of disagreement, which by their nature go round and round in circles, so I will simply bid you adieu.

I really, really wish they had better legal counsel.

I thought the whole issue (not in the present case but in general) is that the hierarchical church can not claim a trust interest in a parish property if the parish property deed holders do not specifically allow that by signing something. 

Or, is that the question about the application of neutral principles versus deference?

Heres a really dumb question for lawyers from an ignorant non-lawyer.

How can someone claim ownership of property if their name is not on the deed, absent some sort of lien on the property?

If the property is not held in the name of the diocese, or in the name of TEC, how can their be a claim to own the property?  I don’t get it.  I’ll bet the catholic churches are in the name of the diocese, not the parish vestry, not individuals or officers of the church, but the entity of the catholic diocese.  There, clearly, the church owns the property.

If this questions is too basic, and has been covered before, I will know by a lack of a reply.  Sorry if it has been answered before.

Ron and DavidH,
There is no real issue respecting a hierarchical church’s desire to centrally control property presented in either this church’s petition or the ruling of the trial court in the Virginia cases.  The point was ably made by Judge Bellows in Virginia, and it is this:  If a church is hierarchical, and it wishes to have the property centrally owned (or at least to record a denominational claim on the property) all it has to do is require that the parishes execute title documents stating the same.  That is what the Roman Catholic church does.  That is what the Episcopal Church has largely failed (but not always failed) to do.  TEC’s unilateral declaration of a trust alone, where it supposedly has the power as a hierarchical church to do the above, should not be respected by the secular courts.  To do so wreaks havoc upon well-settled property and trust principles of law, and unnecessarily raises the specter of consitutional issues under the First Amendment.

Sorry, I meant “Rob” not Ron.

As far as I’m concerned, hierarchical churches must be treated no differently than any other organization, and the Statute of Frauds should always prevail over the Dennis Canon.  In other words, if a parish owns its property, and if they have the deed registered in their name, then they own the property….just as my wife and I own our property outright….even if we were be members of an owners’ association.

I’d even argue that TEC is not a hierarchical church.  Sure it looks like one.  TEC wants you to believe it is one.  But it doesn’t act like one in the sense that you have a common doctrine and exercise of discipline for priests and bishops that act and teach contrary to that doctrine.

For example, a priest in my diocese said something that pointed to a contradiction of what the bishop’s public statements were.  I wrote and asked the bishop to clarify, he wrote back saying he was not responsible for what this person says.  So if a priest can put words in her bishop’s mouth and the bishop disavows responsibility for it, you don’t have a hierarchy.  You have an anarchy.

#17 this is a really complex question, but I will give you a very very oversimplified answer that may vary from state to state. 

The answer lies in what we mean by ownership of property.  When one owns property, all one really possesses is a bundle of rights associated with that property.  Some of the rights are, the right to current possession, the right to future possess, the right to income from the property, the right to transfer title to the property, the right to use of the property, the right to grant access to the property, the right to block access to the property, etc. etc.

While most of the time all of these rights are vested on one or more persons or entities, the law permits otherwise.  In order to allocated specific rights in specific property to differing parties, Trust law developed.  Under trust law one party, the Trustee, holds legal title, while another party or parties, the beneficiary or beneficiaries, hold equitable title.

Thus while the deed may show, John Doe, holds legal title to the property.  Someone else, say Jack Doe, may hold equitable rights in the property.  As a result, if you have a 3 year old son, your will may leave your house to your brother, in trust for your son, to be used for his benefit and to be turned over to him at a specific age; or to be sold and used for his benefit.  The title records would show your brother as legal owner, but your son would have equitable rights. 

To complicate this further, courts recognize the concept of constructive trust.  I.E. I might turn over property to you, with the unwritten understanding between us that you will use it in a certain way. 

So for example, I might say, Paul, I am about to die.  I have $150,000 house that I want you to use to help my son get though college.  Would you be willing to hold this house, rent it out, use the income for my son and then sell the house and use the money to send him to college.  If you agree, but we have nothing in writing, you hold the house in constructive trust.  If you then sell the house and use the money for your personal benefit, my son could sue you.

Again this is very oversimplified, and the rules may vary from state to state.

My wife and I own our home outright with the mortgage paid in full, and we have established a revocable trust.  It seems to me that it would’ve been the advisable thing for a parish to do with their property, along with incorporation, before the Dennis Canon was “enacted.”

Looking for Leaders (#18), you can read a simple summary of how the Episcopal Church claims its Dennis Canon puts a trust on all local church properties at the Curmudgeon’s site. There are links on that page to other posts that take up the subject in as much detail as you could ever want.

If one joins a club and promises to play by the rules of that club, the rules of the club are changed in a way that is objectionable to you but you continue to pay your dues, make solem oaths to God to uphold the rules of the club, call your self a member of the club, don’t object to the rule change until 30 years later and finally when the rules are changed about another important matter, claim to be able to leave that club without regard to the rule change made 30 years ago
then you would be taking a most unreasonable position and will not find sympathy in any court. 
St. James claim that the trust was imposed unilaterally without its consent does not pass what lawyers and judges call the “smell test.”  the argument that st james participated and voted at many gen convs, paid its dues for 30 years, participated and benefitted from the pension plan, called itself a member of TEC, never objected to the Dennis Cannon,
but now can reject the Dennis Cannon,
does not pass the smell test.  Ask the judge who ruled on Matt Kennedy’s argument. 
There is no way the Supreme Court is going to grant cert.
st james just paid Ed Meese (who really is a nice guy despitie all the bad press) a whole bunch of money for nothing.

Seeking Truth - Thank you. 

But, can an entity with which you have an affiliation claim a trust interest in your property without your explicit consent and no paper exchanging hands?

I don’t know what role he had in the drafting of the petition, but it seems like everyone that knows Ed Meese shares the same impression—he is one of the nicest, most earnest public servants of this generation. He was never taken in by Washington, and never thought to highly of himself.

#26, reformedanglican,
I don’t know about your equity argument, reformedanglican.  The truth of the matter is that many local parishes probably never heard of the Dennis Canon until recently.  Some probably still haven’t heard of it.  Moreover, if you assume to the contrary that they knew all about it, why should they have complained, hired lawyers and raised a stink if, as is the case in many states, unilateral or implied trusts were considered of no legal effect?  The real question is, as I stated in post no. 19, why hasn’t TEC avoided all of this ambiguity by simply requiring that every parish record title documents evidencing TEC’s and the Diocese’s interest in the property?  That works for the Roman Catholics.

Does anyone know the history of splits before the Dennis Cannon?  For example, did the REC leave with their property?  What about groups that split in the 1970’s but before Dennis?

An another note, even if it is totally just and consistent with Anglican polity for the leavers to take their buildings and TEC is doing a massively illegal property grab, ultimately, we will look bad if we keep dragging things out in court.  Please consider how the following words apply to those caught up in property battles:

“Do not resist an evil person. If someone strikes you on the right cheek, turn to him the other also. And if someone wants to sue you and take your tunic, let him have your cloak as well. If someone forces you to go one mile, go with him two miles.”

and from a less reliable source:

“Let goods and kindred go, this mortal life also;
The body they may kill: God’s truth abideth still,
His kingdom is forever.”

Think also how cheerfully Polycarp and other early Christians went to their martyrdom, praising God that they had been counted worthy to suffer for the name of Christ.  Can’t we let the pipe organ and a little stained glass go?

Rob Kirby,
I believe since having had a conversation with Bishop Morse from the Anglican Province of Christ the King APCK) that the Dennis Canon came into being after the 1977 exodus of TEc clergy. laity, and churches when they formed their Province and signed the affirmation of St. Louis. Bishop Morse had told my husband and myself that even though they were sued by TEc they won in court and then the Dennis Canon was drafted and put into play.
http://www.anglicanpck.org/index.html

The question then is, was the Dennis Canon ever actually enacted, and where is the proof?  Where are the actual transcripts?  If they’re in TEC’s Archives, why do Schori and Company refuse to release them so that they can prove that the Dennis Canon actually was passed?

Ah! Cennydd, that is the #64 million dollar question that has not gotten the attention that it is due.

Chancellor, 15, if I am not giving you the answer you wanted to hear, that’s too bad. 

You acknowledge that the law allows a state to apply deference or neutral principles.  You then say, as if stating an indisputable law of the universe, that a state that applies “neutral principles” must apply only principles that pass some sort of “truly neutral” test.  You’re can stake out that position, of course.  But Jones v Wolf did not decide what neutral principles are, states have developed their own versions of them, and there is no law of which I am aware that prohibits a state from adopting a version of neutral principles that gives significant weight to the governing documents of a hierarchical church.  (Indeed, many who favor separatists criticize neutral principles in many states as not being all that different in practice than deference.)

It is also true that one can justify virtually any church property principle with an appeal to some other “neutral” principle of law.  (The law is either wonderful or terrible in that it has many principles, which often conflict, and then also allows many distinctions based on individual situations.)

Other things that must be taken into account include that religion will always be special and never exactly the same because of the First Amendment and because of the fact that there is virtually no other comparable circumstance with respect to property ownership.  (There are some cases about fraternities or lodges.)

The bottom line in St. James’ petition is that they want every state in the country to be like New Hampshire (overturning the rules from dozens of decisions and well over a hundred years of precedent in the process).  Good luck convincing a states’ rights friendly Supreme Court on that one.

P.S.  Do current civil rights laws apply to membership in a church?  That statement surprises me.  Private clubs can generally do whatever they want, I thought (thus, you can have men-only, women-only, white-only, straight-only, or other membership rules that don’t fly with respect to public benefits or government).  Freedom of association and what not.

29 Scot S
If the Dennis Cannon was such a terrible property grab, where was the huge outcry when it was even proposed?  The context was the rollout of women’s ordination.  The revisionists knew there might be an exodous over women’s ordination and they took steps to protect their interests.  What happened is that many leaders of the now reasserters deliberately ignored the liberal drift.  They didn’t inform their parishoners.  The rector of my former large sophisticated reasserter parish told me as late as 2001 that he deliberately kept the facts of the liberal drift from his praishioners.  Even as late as 2007 when I as a member of the vestry tried to get my parish to face the reality of the liberal landslide, I was told to be quiet, Bp Duncan was handling it.  So the leaders who were at the gen conv where it was proposed should have raised the alarm.  They should have made sure at the next convention that it was not really passed.  You mean to tell me that there were legitamate arguments that it did not really get enacted and not one single reasserter raised one motion at the next possible opportunity?  Nonsense.  If no one objected then, they don’t deserve to raise the argument now. 
This is just a theory, but my understanding is that the dennis cannon was not perceived to be so bad back in 79 because most understood the PECUS to be a hierarchiacal church.

I was in Denver in 1979. My sense was that General Convention was acting against a threat that congregations would leave because of WO and the 1979 BCP. This convention left open the possible use of the 1928 BCP by providing for use of its “texts.”

I’m preaching to the choir here, but when people question where was the outcry and/or imply there wasn’t one, we need to let them know that there was an outcry and it was ignored for either agenda or the lack of backbone or understanding to fight.  Some have fought, and fought hard and bear the scars for it.  I personally have been told by three priests over the years, “we don’t have to worry about that here”.  And was dismissed - even by “orthodox” priests who didn’t and still don’t get it.

I’ve written it before, but it bears mentioning to those just joining the “party”.  My church in Cent. FL questioned about leaving when WO was approved.  The discussion of the Dennis Canon was concluded when we were told by leadership that we “wouldn’t have to worry about that here.”  Those who were concerned had their hands patted until it was, apparently to the congregations who have left here in CFL, too late. 

There are many of us that watched this, trusting our priests and diocesan leadership over the last 30 years specifically.  And are now betrayed.  Why did we trust?  Because that’s what followers of Christ were supposed to do - follow our sheperds.  Blind faith.  And we’ve been robbed blind.

We were told we could use the 1928 BCP, weren’t going to be forced into accepting WO - women priests.  The “Anglican tent is big enough for all.”  So far, every promise that was made to me, my family, and my parish family was a blatant lie. 

So you want to know where the outcry was?  It was in the pews with nowhere to network and share it.  Now, with the internet and resources like SFIF and T19, etc., we have the ability to speak up and really be heard.  And make changes - like letting the community know about Thew Forrester and the like.  It may be too late to salvage the TEC I grew up in, but it wasn’t because we didn’t speak up.  It was because leadership had their own agenda and ignored us pew potatoes.  The fact that revenue and attendance/membership continues to decrease shows that when you aren’t listened to, you walk.

Amen! Lakeland Two, well put and said and right on. You are in my prayers.

[36] and [31]
Thanks for the history.
So, at least as late as the 1970’s dissenting parishes were able to leave using secular property deeds as proof of ownership.  Then Dennis asserted ownership over the property to stem the tide.  It came about in an adversarial/reactive context rather than (or at least alongside) clarifying ecclesiology.  It seems like the historical context should be noted in court, although the 30-year interval between passage and complaint does not help.

I know nobody on the board was around at the time, but does anyone know the history about the REC and property?

reformedanlgican #35, you write in response to me:
</blockquote>You mean to tell me that there were legitamate arguments that it did not really get enacted and not one single reasserter raised one motion at the next possible opportunity?  Nonsense.  If no one objected then, they don’t deserve to raise the argument now.  </blockquote>

I never said what you are stating I said; other may have.  I have since read many pieces suggesting there were irregularities concerning the passage of the Dennis Canon, but I actually agree with you on that point - if it there were procedural irregularities, the time to raise them was in 1979.  I accept that TEC has had the Dennis Canon on its books since 1979.
However, my point was that your factual suggestion that everyone knew about and accepted this is questionable.  Many local parishes have not had any inkling that a thing like the Dennis Canon existed until recently.  (Some may still not know.)  And, as noted above, if you do know about it, but such a provision is unenforceable and of no force and effect under your state’s property law, why should you care that much?  You still haven’t answered my question:  Why hasn’t TEC simply required that the title documents of the real property of each parish reflect its ownership rights and those of the Diocese, if it is hierarchical like the Roman Catholic church and everyone has always accepted this proposition?

#40-Scott:

I have since read many pieces suggesting there were irregularities concerning the passage of the Dennis Canon

Actually research by Dr. Conger who physically looked at the archived documents of that convention could not substantiate conclusively that the canon actually met all the standards to pass as set by canonical procedure. So far the courts have not addressed this as yet as far as I know. So it may be a canon just because BeerKat says it is. I know…hard to believe she would do that.

Many local parishes have not had any inkling that a thing like the Dennis Canon existed until recently.

Bp O’Neil of Colorado admitted that exact point under oath at the Colorado Springs trial.
Intercessor

Re 41 Intercessor
Igorance of the cannons is no defense.  Not in law or in the church.  Especially for a Bishop who is chagred with upholding such cannons. 
Whatever George Conger found, it is way way too late to raise that argument now.  If someone thought it was irregular they should have raised it at the next possible opportunity.  Or maybe three years later.  Or maybe when the recent troubles began in 2003.  Why did noboby seek to have the dennis cannon declared invalid at least in 2003.  Answer because they would have lost that argument in TEC.  If you call yourself part of a club you are bound by the rules of the club.  30 years of paying dues and calling yourself a member of the club constitute a waiver of any argument that the cannon passed so long ago was not validly enacted.  Making such arguments only undermines reasserter credibility.  It doesn’t pass the smell test.

#42-Rubbish…
Intercessor

#42 Reformedanglican,
The parishioners who are being sued for their buildings and property have broken no civil laws. And there are many former and continuing TEc-ers who never knew of the Dennis Canon until here of late. Those are just the facts….none of them k=knew that it was something they needed to know because it wasn’t something made widely and openly known until these past few years. MAybe those who wnet to hat Convention and discussed the Dennis CAnon and supposedly passed it knew but no one has had need to know of it until here of late and there is question as to its validity. Courts more times than not care not one with about our canons as they do not enforce them, they are not civil laws.