Order of St. Benedict of N.J. v. Steinhauser

In Order of St. Benedict of N.J. v. Steinhauser (234 U.S. 640 [1914]) the Order of St. Benedict sought to establish its title to personal property left by a deceased member of the Order, suing the administrator of the estate of the decedent. The Order followed vows of obedience, stability, chastity and poverty. Each member pledged to have all property that he now holds or hereafter holds conveyed to the Order. The decedent was member of the Order. He published many works on religious subjects and obtained the copyrights for these books and entered into contracts with publishers. He was paid royalties during his lifetime, and after his death, the royalties were paid to his estate. The Supreme Court stated that it was clear from the principles of the organization that the decedent was not entitled for his own benefit either the monies he received for his services in various churches to which he was connected or those he derived from the sales of books. The Supreme Court ruled that the Order had a valid claim to the interposition of a constructive trust. It stated that the case did not involve "any question of ecclesiastical requirement or monastic discipline. The question is solely one of civil rights. The claim in suit rests upon the constitution of the complainant organization and obligations inherent in membership" (Order of St. Benedict of New Jersey, 234 U.S. at 642).