The Church of Christ (Temple Lot)
Among the churches that emerged from the 1844 succession crisis, one group holds something none of the others do: physical possession of the exact two-acre parcel in Independence, Missouri that Joseph Smith personally dedicated in 1831 as the site of a future temple. That group is neither the LDS Church nor Community of Christ. Its right to hold that ground was the subject of a five-year federal lawsuit that ended without either side clearly winning.
Three churches each claimed to be the rightful heir of the same founding prophet. A federal court heard all three arguments and declined to decide any of them.
Origins
Followers of Granville Hedrick organized as an independent branch as early as 1863, formally taking the name "Church of Christ," the name under which Joseph Smith originally incorporated his church in 1830, specifically to distinguish themselves from both the Utah church and the RLDS Church. Hedrick reported a revelation in 1864 directing a return to Jackson County, Missouri. His brother John Hedrick led the first arrivals in 1865, and the group purchased lots making up the Temple Lot itself in 1867, decades before either the LDS Church or the RLDS Church made any comparable move to reclaim the specific ground.
Of the three parties that would eventually contest the property in court, the Hedrickites were the only one to have physically returned to and occupied the original site.
Three claims, one lot
Claimed ownership on the basis of legal title: they held the purchased deeds to the property and had occupied it continuously since 1867.
Claimed the property as the rightful legal successor to the original 1830 church, arguing the land had been unlawfully seized when Missouri mobs drove the Saints out in 1833.
Not a party seeking the land itself, but funded and advised the Hedrickites' defense specifically to prevent the RLDS Church from winning a legal ruling that it was Joseph Smith's sole legitimate successor.
The suit
Construction of a small meetinghouse on the Temple Lot in 1887 prompted the RLDS Church to serve a cease-and-desist notice. When the Hedrickites continued building anyway, the RLDS Church filed suit in the United States District Court for the Western District of Missouri on August 6, 1891.
Suit filed
The RLDS Church sues the Church of Christ (Temple Lot) for possession, arguing legal succession from the original church.
Trial court rules for the RLDS Church
After hearings beginning February 1894, the trial court holds that the RLDS Church is the rightful successor to the original Latter Day Saint church and therefore entitled to the property. It separately rules that the legal doctrine of laches (unreasonable delay in asserting a claim) does not bar the RLDS claim, since mob violence had prevented the Saints from asserting their rights sooner.
Appeal
The Hedrickites appeal to the United States Court of Appeals for the Eighth Circuit. During the case, LDS Church leaders, including church president Wilford Woodruff, called as a witness, testify, and the litigation becomes a significant source of court testimony documenting Joseph Smith's practice of plural marriage, introduced specifically to counter the RLDS Church's claim of direct doctrinal continuity with Smith.
The appeals court disagreed with the trial court's reasoning on laches, suggesting the RLDS Church had in fact delayed unreasonably in asserting its claim, and further suggested, in passing, that the Hedrickites' legal title was probably the stronger of the two. Rather than reversing the trial court's decision outright in the Hedrickites' favor, the appeals court dismissed the case from the courts entirely, leaving the matter exactly as though no suit had ever been filed. The RLDS Church's request for a second hearing en banc was itself dismissed.
The practical result: the Hedrickites retained the Temple Lot by default, because they were the ones standing on it when the litigation ended inconclusively. They have held it without further serious legal challenge ever since.
Two vindications from one ambiguous result
RLDS reading
Joseph Smith III and his successor Israel A. Smith argued the RLDS Church had been denied title only on the technical ground of laches, and that the courts had otherwise confirmed its superior claim to be Joseph Smith's rightful successor: a moral and doctrinal victory even without possession of the land.
Hedrickite reading
The Church of Christ (Temple Lot) has consistently maintained that the case stands as final validation of its right to the property, citing the appeals court's own suggestion that its title claim was the stronger one, and the fact that it, not the RLDS Church, has physically held the ground for over a century since.
No later legal challenge has reopened the question. In the 1930s, the Hedrickites began excavating the site to finally build the temple Smith had designated it for in 1831. The effort stalled amid the Great Depression and internal disputes, and the excavation was filled back in by 1946. No temple has been built there. The lot today holds only the small Church of Christ headquarters building and a scattering of trees, directly across the street from Community of Christ's own, very different Independence Temple, completed and dedicated in 1994.
Reading this against the -ites pattern
The Temple Lot Case is the clearest instance on this site of the -ite pattern being litigated rather than merely argued. Three churches, each descended from the same 1844 fracture, each claiming to be the authentic continuation of Joseph Smith's founding church, brought their competing claims of legitimate succession before a federal court. Faced with the actual evidentiary record, the court could not cleanly award the title of "rightful successor" to any of them. What decided the outcome was not doctrine, descent, or revelation, but simple physical possession and the passage of time — the same "out-wait" mechanism documented on The Speaker and the Room, operating here not through church office, but through a federal docket.
Sources
- "Temple Lot Case," Wikipedia.
- "Temple Lot Case," Religion Wiki (Fandom).
- Mormonism Research Ministry, "Splinter Group: Church of Christ (Hedrickites, Temple Lot)," mrm.org.
- "Church of Christ (Temple Lot)," Wikipedia.
- "Temple Lot," Wikipedia.
- S. Patrick Baggette II, "The Temple Lot Case: Fraud in God's Vineyard," John Whitmer Historical Association Journal 23 (2003): 121–136.
- Liquisearch, "Temple Lot Case – Trial."
- By Common Consent, "The Temple Lot: Visions and Realities," citing Jean Addams, "The Church of Christ (Temple Lot), Its Emergence, Struggles, and Early Schisms."
- Gospel Tangents, "How a Tiny Church Battled for the Temple Lot," interview with historian R. Jean Addams.
- Reorganized Church of Jesus Christ of Latter Day Saints v. Church of Christ, 60 F. 937 (C.C.W.D. Mo. 1894).