The Temple Lot Case, formally known as “The Reorganized Church of Jesus Christ of Latter Day Saints v. Church of Christ,” was a legal dispute that took place from 1891 to 1896 over the ownership of a parcel of land in Independence, Missouri. This parcel of land is historically significant to members of the Latter-day Saint movement and its off-shoots because it was designated by Joseph Smith, the founder of the movement, as the site for a future temple. This is where the court case gets its name because it was designated as the Temple Lot.
Historical Background
In 1831, a year after formally organizing the church, Joseph Smith revealed Independence, Missouri as Zion, a gathering place and a New Jerusalem. Smith also designated a site for the temple in Independence. This revelation is canonized in Doctrine and Covenants 57. Verse three states “Behold, the place which is now called Independence is the center place; and a spot for the temple is lying westward, upon a lot which is not far from the courthouse.” This site became known as the Temple Lot. The church purchased the lot and placed a cornerstone on it on August 3rd.
Due to intense persecution, the Latter-day Saints were driven out of Missouri, and the land remained undeveloped. They moved to Illinois and built a new city and temple in Nauvoo. In 1844, Joseph Smith was killed by a mob in Carthage jail after submitting himself to a warrant issued by a Carthage judge. After Joseph Smith’s death, many members of the church broke away from the main body of the church and created their own churches. The main body of the church moved to Utah and continued to practice (Joseph Smith’s) polygamy. One of the splinter groups was the Church of Christ, they were also known as the Hedrickites because they had been formed by Granville Hedrick in 1863. In 1867, the Hedrickites returned to Independence and purchased the deed to the Temple Lot.
Another group was formed by Joseph Smith’s son, Joseph Smith III. Joseph Smith III believed he was the rightful successor of the Latter-day Saint movement. He did not recognize the church that had moved to Utah, under the leadership of Brigham Young, as the same church his father founded. In 1860, Joseph Smith III reorganized the Church of Jesus Christ of Latter-day Saints, officially renamed the Reorganized Church of Jesus Christ of Latter Day Saints (RLDS Church, now known as Community of Christ) in 1872.
The Dispute
The Church of Christ, or Hedrickites claimed ownership of the Temple Lot. Their argument was that they owned the lot because they had possession of the land deeds. However, the RLDS Church, led by Joseph Smith III (son of Joseph Smith), also claimed ownership. They argued that they were the legitimate continuation of the original church and thus had rightful ownership of the property, as it was unlawfully seized when Joseph Smith and the members of The Church of Jesus Christ of Latter-day Saints had been driven out of Missouri by mobs and the Extermination Order. This was the Temple Lot case.
Legal Proceedings
The case went to trial in 1891 in the United States District Court for the Western District of Missouri. The RLDS Church brought the lawsuit against the Church of Christ to establish their claim to the property. One of the ways that the Hedrickites sought to discredit the RLDS’s claim of being the true successors of the original church organized by Joseph Smith was to establish that one of the original doctrines taught and practiced by Joseph Smith was plural marriage.
The evidence that the Hedrickites needed to prove that Joseph Smith practiced plural marriage had to come from members of The Church of Jesus Christ of Latter-day Saints, now living in the Intermountain West, (mostly Utah), and the evidence needed to particularly come from Joseph Smith’s plural wives. Three women, Emily Partridge, Lucy Walker, and Malissa Lott, testified that they were married to Joseph Smith as plural wives and had a marriage relationship that included sexual relations.
OutcomeIn 1894, Judge John F. Philips ruled in favor of the RLDS Church. However, the Hedrickites appealed the decision. The appeals court dismissed the case on appeal, making it as if the case had ever come to court, which reverted ownership to the Church of Christ. The RLDS Church appealed again, but the case was never taken by the Supreme Court. The Hedrickites have retained ownership of the Temple Lot property to this day.
By Todd Noall, Source Expert
Todd Noall is an author and religious scholar at Mormonism Explained with a focus on the history and theology of religion.
Fact Checked by Mr. Kevin Prince, Source Expert
Kevin Prince is a religious scholar and host of the Gospel Learning Youtube channel. His channel has garnered over 41,000 subscribers and accumulated over 4.5 million views. Mr. Prince also created the Gospel Learning App, a reliable platform where individuals seeking truth can access trustworthy answers to religious questions from top educators worldwide.
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