Young Life Campaign v. Patino

In Young Life Campaign v. Patino (1981) 122 Cal. App. 3d 559, the Court of Appeal for the Third Appellate District considered whether an organization was a "church" within the meaning of the Unemployment Insurance Code. The court adopted an approach used by the Internal Revenue Service to determine what is a "church," which the Court of Appeal described as follows: "Rather than defining 'church,' the IRS admits its inability to formulate a definition, and applies criteria derived from the forms and practices observed in recognized churches, without giving controlling weight to any. " ( Id. at pp. 574-575.) The criteria for defining a church applied by the Internal Revenue Service were set forth in a footnote and included: " '(1) a distinct legal existence, (2) a recognized creed and form of worship, (3) a definite and distinct ecclesiastical government, (4) a formal code of doctrine and discipline, (5) a distinct religious history, (6) a membership not associated with any other church or denomination, (7) a complete organization of ordained ministers ministering to their congregants, (8) ordained ministers selected after completing prescribed courses of study, (9) a literature of its own, (10) established places of worship, (11) regular congregations, (12) regular religious services, (13) Sunday schools for the religious instruction of the young, (14) schools for the preparation of its ministers.' " ( Id. at p. 574, fn. 15.) The Court of Appeal observed: "A similar approach to the meaning of 'religion' was recently taken in an illuminating law review note: 'Religion can be described and exemplified in ways that disclose "a complicated network of similarities overlapping and criss crossing." Unraveled, the various strands do not amount to "religion" for the meaning of the network resides in the interweaving itself. Thus, it is exemplary and not exhaustive to say that religion involves traditional theistic beliefs, or belief in something parallel to an orthodox conception of God, or an ultimate concern, or a set of beliefs that "address themselves to basic questions about the nature of reality and the meaning of human existence." A non-analytic understanding of religion is not boundless, for the network of similarities always includes a binding of the individual to something unrelated to individuality, through the intense operation of faith. No one element or set of elements constitutes a necessary and sufficient condition for religion; presence or absence of an element can neither establish a religion, nor prevent a belief from becoming a religion.' ( Young Life Campaign v. Patino, supra, 122 Cal. App. 3d at p. 575, fn. 17.)