Appeals Court Upholds Dismissal of Tithing Lawsuits Against Church of Jesus Christ

A three-judge panel of the 10th Circuit Court of Appeals issued a unanimous ruling on Monday in a consolidated class-action lawsuit over tithing against The Church of Jesus Christ of Latter-day Saints. The judges affirmed a 2025 district court decision that dismissed the case, which had been brought by nine people across four lawsuits. The plaintiffs sought the return of hundreds of thousands of dollars they had donated to the church over about 25 years.

Three plaintiffs, Daniel Chappell, John Oaks and Masen Christensen, filed a proposed class-action complaint in the U.S. District Court for the District of Utah in October 2023. Other plaintiffs then filed similar cases in federal courts in California, Tennessee and Washington. A judicial panel consolidated the cases, which were heard together in U.S. District Court in Salt Lake City.

The plaintiffs alleged that the church fraudulently induced donations, misused donations and concealed the alleged misuse. They also alleged that the church committed fraud when it said tithing funds would be used only for church purposes, and that it engaged in illegal “enrichment” by keeping the funds. The church has disputed the claims.

In April 2025, Judge Robert J. Shelby ruled that all the plaintiffs should have been aware of the information behind their claims more than three years before they sued. The law bars such lawsuits when they are not filed within three years. Shelby dismissed the case with prejudice, meaning the nine plaintiffs could not refile it, and the plaintiffs appealed to the 10th Circuit. Deciding whether the claims were brought in time required the court to weigh when the plaintiffs knew or should have known the relevant facts, a question of fairness to both sides (Proverbs 18:17).

In its opinion, the panel wrote, “We see no reversible error,” and, later, “We are not persuaded.” The judges, Harris Hartz, Gregory Phillips and Nancy Moritz, were reviewing whether the district court had erred in finding the suits were filed too late, according to the report.

Church spokesman Sam Penrod said after Shelby’s 2025 ruling that tithing donations “are an expression of faith and allow the church to fulfill its divine mission.” He said the donations “are carefully used and wisely managed, under the direction of senior church leaders,” and that “the legal claims brought against the church were rightfully dismissed by the court.”

The church has now won three major cases in 20 months involving claims about tithing. Hartz and Phillips served on the panel in both the Gaddy ruling and Monday’s consolidated decision. The judges in the Huntsman and Gaddy cases also declined to decide the tithing portions of their rulings on church autonomy grounds.

Monday’s ruling also left unaddressed the issue both sides had wanted the court to consider: the church autonomy doctrine, which allows religious bodies to determine their own doctrines, policies and use of donated funds. Many religions have said they want a high court precedent supporting church autonomy regarding religious donations, and the plaintiffs had hoped for a ruling that would reject it. An attorney who filed a friend-of-the-court brief on behalf of multiple religions in support of the church had called the case a “brazen and dangerous assault on a church’s religious authority.”

Source: Read the original report