An interesting case was recently decided by the United States Court of Appeals for the Sixth Circuit. It involved issues about the role of the Courts in deciding disputes between religious organizations.
In General Conference Corporation of Seventh-Day Adventists v. McGill, the Court of Appeals found for the Seventh-Day Adventists in a lawsuit against Walter McGill and the Creation 7th Day Adventist Church. This case arose out of a trademark dispute between the General Conference Corporation of Seventh-Day Adventists and Walter McGill, the founder of the Creation 7th Day Adventist Church.
McGill was originally a member of the Seventh Day Adventist church affiliated with the Plaintiffs. After a theological dispute, McGill split and formed his own church called “Creation 7th Day Adventist Church.”
The Seventh Day Adventists had previously trademarked the name “Seventh Day Adventist.” The Seventh Day Adventists brought suit against McGill for trademark infringement and the Court of Appeals upheld the District Court’s order granting summary judgment in favor of the Seventh Day Adventists.
McGill first argued that the Court lacked subject matter jurisdiction over this dispute because the Court would have to analyze religious doctrine in order to determine which party was the true 7th Day Adventist. McGill argued that there could only be one true 7th Day Adventist and that the Court of Appeals lacked jurisdiction to determine which party was the true Seventh Day Adventist.
Rejecting this argument, the Court of Appeals held that “trademark law will not turn on whether the plaintiffs’ members or McGill and his congregants are the true believers.” The Court of Appeals found that it could use neutral principles of law to decide this trademark case.
McGill next argued that his rights were violated under the Religious Freedom Restoration Act (RFRA). Specifically, McGill argued that enforcement of plaintiff’s trademarks would violate his free exercise clause because his religion mandates him to call his church the “Creation Seventh Day Adventist”. Essentially, he argued that although he might be violating the trademark law, his religion required him to do so.
The Court of Appeals also rejected this argument. The Court of Appeals found that even though an individual is bound by his religion to act or not act, he must still obey the law. Further, the Court of Appeals found that the RFRA only applies to suits where the government is a party. The Court of Appeals reasoned that Congress did not intend the RFRA to apply to private parties.
McGill also argued that the term “Seventh Day Adventism” cannot be trademarked. He argued that the term Seventh Day Adventism referred to a religion and is therefore a generic term, that cannot be trademarked. The Court of Appeals rejected this argument, finding that McGill could not sustain his burden of proving that the public perceived the term Seventh Day Adventist as a religion.
For these reasons, the Seventh Day Adventists were successful in their trademark infringement lawsuit against McGill.
This article was written by Matthew Ehrlich, Legal Clerk at Demorest Law Firm.
