Posts tagged parishes
Today I’ll be discussing Aglikin v. Kovacheff, a 1987 Illinois appellate court case involving a dispute over control of St. Sophia Bulgarian Orthodox Church in Chicago. The key question, in this case, concerns the extent of the diocesan bishop’s authority over the local parish. The bishop had dismissed certain members of the parish board of trustees — did he have the authority to do this? The Illinois court (both the majority and the dissent) applied neutral principles analysis to the case. (To read the full opinions, click here.)
St. Sophia was a part of the Bulgarian patriarchal jurisdiction. It was incorporated in 1946, and its articles of incorporation indicate that it is “administratively and canonically” an “inseparable organic part of the Bulgarian Eparchy in America and under its jurisdiction.”
The bylaws of the Bulgarian Orthodox Church grant diocesan control over local parish boards — according to the bylaws, if parish board members fail in their duties, the diocese can dismiss the board and appoint a commission to run the church. These Bulgarian Church bylaws also stipulate that the “organization and administration” of the American diocese will be determined by a special synodical order sanctioned by the Bulgarian Ministry of Foreign Affairs — but, the court says, “[n]o such order appears in the record before us.” The lack of such an order was a major part of the dismissed trustees’ argument against the bishop’s authority.
The Bulgarian diocese in America was founded in 1969, and its bylaws provide for “absolute control” of church property by the local church, administered by the parish board. The diocesan bishop must bless the election of board members, but the bylaws are silent about any diocesan control over the board once it is in office. Unlike in the patriarchal bylaws, there’s no indication in the diocesan bylaws that the bishop can dismiss board members.
The trial court had applied strict deference in this case, and found that since the local parish is subordinate to the diocesan bishop, it is bound by his decisions. On this basis, the trial court granted summary judgment in favor of the diocesan commission. (Summary judgment means that the case didn’t go to trial — the trial judge decided that there was no “genuine issue of material fact,” and that one side was entitled to “judgment as a matter of law.”) The appellate court disagreed, holding that neutral principles, rather than strict deference, should be employed. Why? “Our preference for a neutral principles approach, rather than the strict deference approach, is based on our conclusion that court entanglement in ecclesiastical doctrine is less likely to occur in the application of neutral principles.”
Deference, said the court, presumes that a local church has totally submitted to a hierarchical authority — but it’s not always that simple. In fact, strict deference may discourage local parishes from affiliating with a diocese, since they would be subject to the whims of the diocesan authority. Citing Justice Rehnquist’s dissent in Serbian Diocese v. Milivojevich, the court observed that strict deference also runs the risk of establishing religion.
Neutral principles analysis isn’t always possible. According to the appellate court, it works in disputes over ownership or control. In this case, both sides agreed that the dispute wasn’t about doctrine or polity — it was about control of property.
Applying neutral principles, the appellate court found that there was a genuine issue of material fact in this case: namely, the extent of diocesan authority. St. Sophia’s articles of incorporation place it under the Bulgarian Church, but they don’t specify the extent of that subordination. Nothing in the articles says that the bishop controls parish property or can dismiss a parish board. Likewise, the diocesan bylaws don’t help. The Bulgarian Orthodox Church bylaws do give the bishop that kind of authority… but that brings us back to that special synod order I mentioned above. There was no such order, at least not that anyone could produce, which led the court to question whether the Bulgarian patriarchal bylaws applied to its American diocese.
This isn’t to say that the patriarchal bylaws don’t apply to America, but it’s enough for the court to find a “genuine issue of material fact” sufficient to send the case to trial. Because of this, and because the trial court erroneously (so says the appellate court) employed strict deference rather than neutral principles, the case was sent back to the lower court. The appellate court reasoned,
We note that the trial court impermissibly extended its jurisdiction by declaring that St. Sophia will be “governed by the dictates” of the bishop. While civil courts have subject-matter jurisdiction over church property disputes, they may decide only issues relating to the parties’ civil and property rights. [...] By according the bishop plenary authority over St. Sophia’s affairs, the trial court failed to restrict itself to deciding who controls St. Sophia’s property and assets. Civil courts lack the power to confer ecclesiastical authority.
In dissent, Justice Jiganti actually agreed that neutral principles analysis was appropriate in this case, but he reached a very different conclusion. Neutral principles is the right approach, he says, but here there simply is no geninue issue of material fact. “The only issue in this case is whether St. Sophia submitted to the jurisdiction of the regional diocese and the Bulgarian Orthodox Church. Although the majority finds a question of fact with regard to this issue, I believe that it is foreclosed by the statement in St. Sophia’s Articles of Incorporation that St. Sophia was ‘administratively and canonically’ under the jurisdiction of the ‘Bulgarian Eparchy in America.’”
These articles of incorporation, says Justice Jiganti, should be analyzed just like a contract — the plain meaning of the words is paramount. And those words plainly subject the local parish to the jurisdiction of the Bulgarian Church. Yes, the parish has some level of choice in certain respects, but it’s still subordinate to the American diocese and the Church of Bulgaria. The fact that the diocesan bishop can replace the parish board doesn’t take control over church property away from the parish — it just changes the identity of the parish leaders. “St. Sophia will still operate as St. Sophia, but under a new leadership.”
Both sides in this case make some good points, but my initial reaction is that the majority’s decision hinges on a technicality. No, there wasn’t that special synod order, but how important is that? Does the absence of a special order mean that the American diocese isn’t subject to the bylaws of the Mother Church? It would be nice to get some more information about just what the special order is, but we aren’t given any details. We’re just told by the majority that there wasn’t such an order. I didn’t discuss it above, but the majority also found some significance in an affidavit by the former president of the parish board, claiming that St. Sophia retained “administrative independence” when it joined the American diocese. The dissent points out that, since we have reasonably clear official documents like the articles of incorporation, that affidavit doesn’t carry a lot of weight.
In defense of the majority, on the other hand, I would point out that they didn’t say that the former parish board wins the case — they just said that there’s enough of a factual dispute that the case should go to trial. They may be right. At the very least, I would think that a trial would reveal the content and significance of those “special orders.”
The most interesting thing about this case is the fact that justices applying neutral principles can still reach very different outcomes in the same case.
This article was written by Matthew Namee.
Prior to Bishop Raphael Hawaweeny’s death in 1915, pretty much all the Syrian (Antiochian) Orthodox in America recognized his authority. This included St. George Syrian Orthodox Church of Grand Rapids, Michigan, which was incorporated in 1910. The parish was under St. Raphael, and all seemed to be well. But in February 1915, St. Raphael died, and his flock split: some recognized the authority of the Patriarch of Antioch, and others the authority of the Russian Holy Synod and its North American Archbishop. This marks the beginning of the “Russy-Antacky” schism, which divided Antiochian Americans for many years.
This split not only divided St. Raphael’s diocese, but individual parishes as well. At St. George in Grand Rapids, the priest came back from St. Raphael’s funeral and told his congregation to sign a declaration of loyalty to the Russian archbishop. Not everyone complied, and pro-Antioch parishioners insisted that their priest commemorate the Patriarch of Antioch in the Divine Liturgy. Meanwhile, the pro-Russian group tried to amend the parish articles of association to place church property under the control of the Russian Holy Synod. The factions went to court, culminating in Hanna v. Malick, a 1923 Michigan Supreme Court case.
The key question in the case is which faction — Russy or Antacky — should have control of the church property. To figure this out, the court had to determine which hierarchy — Russian or Antiochian — was recognized by the parish when it formed in 1910. The Antacky members “claim that they organized under and are subject to the supreme jurisdiction” of Antioch, “whose representative in America was Bishop Raphael of Brooklyn.” The Russy members “claim that this local church was organized under and has always been subject to the supreme jurisdiction” of the Russian Church.
The original parish documents are somewhat ambiguous. Article 2 of the original articles of association describes the purpose of incorporation as follows: “To teach and promulgate the Christian religion in accordance with the tenets and doctrines and creed of the Syrian Greek Orthodox Church of Antioch, Syria, and the Syrian Greek Orthodox Church of America, as expounded by the bishop thereof resident at Brooklyn, New York, U.S.A.”
According to the trial court judge, the articles were prepared by a local Grand Rapids attorney “after he had asked these men under what jurisdiction this contemplated church was claimed by them to be.” Similar language appears in the parish bylaws:
All persons believing in the divinity of Christ, in God the Father and the Holy Ghost, the sacrament of baptism and marriage in accordance with the articles of faith established by the Orthodox Greek Church of Damascus, Syria, shall be entitled to membership. Members are admitted by baptism and by confession of faith under the rules and tenets of the Orthodox Greek Church of Damascus, Syria. They may be suspended or expelled for violation of the teaching and precept of the church as laid down and expounded by the bishop of the Syrian Greek Orthodox Church of America, resident at Brooklyn, New York.
Now, to a casual reader, these documents seem to recognize Antioch. There’s not a word to be found about the Russian Church. But there are references to the Bishop of Brooklyn, and the Russy party used this fact to argue for Russian jurisdiction. According to the Russy group, all the Orthodox in America were under the Russian hierarchy. In fact, they expounded what is, as best I can tell, the earliest coherent example of the “flag-planting theory” for Russian jurisdiction. Here’s how the trial court explained it: “By virtue of having established in the Western Hemisphere a Russian church, and the territory wherein the church was established having been purchased by the United States, the Russian Church now claims the right to rule over and assumes jurisdiction over all Greek Orthodox churches within the United States, regardless of the nationality of the congregation or the membership of the local church.”
But the court wasn’t interested in the jurisdictional claims themselves. It’s not a dispute between Russia and Antioch, but between members of the local parish, for control over a piece of real estate. Because of this, the paramount question is the intention of the original incorporators. “If this were a lawsuit between the Patriarch of Antioch, on the one hand, and the Holy Russian Synod, on the other hand [...] it is possible that a different question might be raised.”
The case, then, boils down to St. Raphael himself. If he was under Antioch, as the Antacky claimed, then their side would win. If he was under Russia, the case for the Russy would be greatly strengthened. So the court looked at St. Raphael’s own writings: what did the man himself say about his jurisdictional position? The following quotations are from St. Raphael’s periodical Al Kalimat, and were translated for the court (brackets in original):
- “That he [Raphael] was consecrated bishop by the order and permission of Melatois, the Patriarch of Antioch.” (vol. 1, page 2)
- “Those who were consecrated bishops through his [Patriarch of Antioch] consent were his grace, Basileus Dibs, the Metropolite of Akkar, Syria, one of the Antiochian dioceses, and the owner of this magazine, the Bishop of Brooklyn, New York, U.S.A.” (vol. 2, page 95)
- “Patriarch Melatois counted the new parish of Brooklyn, New York, as one of the parishes of Antioch.” (vol. 3, pages 95-96)
- “And during his [Melatois'] administration [as patriarch] many unusual things many unusual things took place, such as the demise of several lamented archbishops. For this reason a conclave was had of archbishops, his beatitude presiding, during which conclave there were clected bishops for the seats vacated by such deaths. … Those who received the benediction of ordination into the high priesthood by the sanction of his beatitude are two, to wit, his eminence, Basileus Dibs, archbishop of Akkar, and the editor of this magazine (Bishop Raphael), Bishop of Brooklyn, North America.” (vol. 3, page 95)
- “And the territorial jurisdiction of the See of Antioch became much more extensive during the time of his beatitude, for Syrians who emigrated to many other countries still retained their spiritual relations with and continued to acknowledge and yield allegiance to their mother church, the Holy Church of Antioch, and kept firm in the Orthodox faith. His beatitude manifested the most perfect evidence of his interest in and care for them to the best of his means and ability. In substantiation of this, when the Russian Holy Synod informed him that the lot of presiding in this diocese [the diocese of Brooklyn] had fallen upon our humble self [Raphael], his beatitude hastened to write to the Holy Synod, to His Eminence Tikon, then Archbishop, and to our humble self, sanctioning the choice and declaring that he [his beatitude] had instituted this new diocese as one of the dioceses pertaining to the See of Antioch and thus it is in actuality, notwithstanding its nominal allegiance to the Russian Holy Synod.” (vol. 3, page 95)
- “Whereas, we, the Syrian Orthodox residents of Greater New York and all other parts of North America constituting our new diocese (may God keep it) are considered a vigorous branch of our mother tree, the Church of Antioch; and whereas, this branch has flourished luxuriantly during the days of the administration of our father, may his name be ever blessed, the thrice illustrious Patriarch Melatios; and whereas, his beatitude was the first to sanction and bless the establishment of this new Syrian diocese in this new world.” (vol. 2, page 18)
The trial judge observed that “at first the writings of Bishop Raphael gave to the Patriarch of Antioch jurisdiction over the Syrian branch of the Orthodox Church in the United States, and later gave expression to language indicating that all the branches, including the Syrian branch, of the Greek Orthodox Church in America, were under the jurisdiction of the Holy Synod of Russia.” Without a clear-cut answer from St. Raphael’s own writings, the judge looked at two non-Orthodox sources: Funk & Wagnalls’ Religious Encyclopedia and the Encyclopedia Britannica. The former reported that “the Patriarch of Antioch elevated Raphael to the rank of bishop” (but that Raphael was consecrated by Russian hierarchs), while the latter noted that the Russian archbishop in America “is assisted by two bishops, one for Alaska [...] and one for Orthodox Syrians, residing in Brooklyn.” The secular sources don’t seem to settle things, either.
Texts being insufficient, the judge moved on to consider actions. He observed that “the record shows but one instance where he [Raphael] was directed by any church authority.” That instance was in August 1910, when St. Raphael announced in Al Kalimat an order he had received from the Patriarch of Antioch regarding marriages of Syrian Orthodox in America. In addition, in 1901, St. Raphael wrote that he had received a telegram from the Patriarch informing him of his election as Metropolitan of Salefkias. St. Raphael declined, but the judge saw this as evidence of a relationship between Raphael and Antioch. Furthermore, according to the judge, “It is not shown in this case that during the life of Raphael the authorities of the Russian Church in any manner gave any orders to the Syrian branch of the church, or attempted in any way to direct the actions or utterances of Raphael in his relations with the Syrian Church.”
There are some flaws in this reasoning. Yes, we can establish that there was a close relationship between Raphael and Antioch, but there was also a close relationship between Raphael and the Russian hierarchy in America. It was St. Raphael who, as an archimandrite, welcomed St. Tikhon to America in 1898, and Tikhon and his auxiliary Bishop Innocent were the ones who actually consecrated Raphael in 1904. It was St. Raphael who blessed the land on which St. Tikhon’s Russian Orthodox Monastery was built, and there are countless examples of Raphael working with the Russian Archdiocese in America. The Russians themselves clearly understood Raphael to be one of theirs, and in his 1905 plan for Orthodoxy in America, St. Tikhon includes the Syrian bishop as a crucial part — while at the same time recognizing that Raphael was “almost independent in his own sphere.”
Both parties have a legitimate argument in this case, but as the judge consistently reiterated, this case is ultimately about the intent of the original incorporators of the Grand Rapids church — not about the relative claims of Russia and Antioch in America. Those claims are relevant only insofar as they help us better understand the incorporators’ intent.
In the end, the trial court sides ruled in favor of the Antacky group — that is, as best as the court could determine, the original parish incorporators intended to be under Antiochian jurisdiction. The court based its decision largely on the references to Antioch in the parish documents. Yes, those documents also refer to the bishop of Brooklyn, but the judge saw insufficient evidence to conclude that Raphael was under Russia rather than Antioch. The Michigan Supreme Court upheld the judgment (and, indeed, hardly added a word, mostly quoting directly from the district judge). The Michigan Supreme Court did note that, in light of the chaos that followed the Russian Revolution, “the precautions taken in organizing this Syrian church seem to have justified themselves.”
This is a terribly fascinating case from a historical perspective, and tells us a lot about how the early Antiochians in America thought about themselves. But what are the legal lessons we can learn? The district court judge — affirmed by the state supreme court — could not have employed “deference to higher church authorities” if he had wanted to, since the entire dispute was over which was the correct higher church authority. The judge was forced to employ something along the lines of a neutral principles analysis. Did he get the right answer? Well, it depends on the question. The judge was trying to figure out the intent of the original incorporators, and based on the language of the official documents, it does seem like they intended to be under Antioch. Were they really, in fact, under Antioch? What would the outcome be if the claim was between Antioch and Russia themselves, and actual jurisdiction had to be determined? That is a much, much more complicated question, to which there isn’t a single, clear-cut answer.
This article was written by Matthew Namee.
In March, I gave a lecture at Holy Apostles Greek Orthodox Church in Westchester, Illinois, on the subject of Chicago’s Orthodox history. Since then, I’ve begun to probe deeper into the early history of Orthodoxy in Chicago. Many people have asked about one man in particular — George Brown, an early leader of Chicago’s Orthodox community.
At a landmark meeting of the Chicago Orthodox in 1888, Brown was elected president of the fledgling multiethnic proto-parish. He offered this speech (reported in the Chicago Tribune the following day, 5/14/1888):
Gentlemans, union is the strength. Let everybody make his mind and have no jealousy. I have no jealousy. I am married to a Catholic woman but I hold my own. Let us stick like brothers. If our language is two, our religion is one. The priest he make the performance in both language. We have our flags built. It is the first Greek flags raised in Chicago. We will surprise the Americans. Let us stick like brothers.
The Tribune also reported that Brown was a veteran of the American Civil War. Three years later, the community was still trying to start a full-fledged parish, and Brown was still in a leadership role. From the Chicago Inter Ocean, we learn that “Mr. George M. Braun, a Greek, who is one of the leaders in the movement for a church in this city, says that they have been promised a priest of the orthodox faith as soon as they have erected a church.” Ultimately, no multiethnic parish was founded; instead, separate Greek and Russian churches were established in 1893.
Four years later, Greece was on the brink of war with Turkey, and thousands of Greek Chicagoans prepared to return and fight for their home country. The Tribune (2/15/1897) reported,
George M. Brown, a barber, No. 32 Wells street, and, in spite of his English name, of pure Greek blood, was seen last night at his home in North Market street, between Kinzie and Michigan. He rubbed his hands gleefully when told of the latest cable news.
“I am glad to hear this,” he said. “There are 2,000 of my fellow-countrymen in Chicago who will return to their native land to fight against the hated Turks. I hope it will end in driving the Musselmans [Muslims] out of Europe. We have been holding meetings for some time and almost without exception the Greek residents are anxious to fight. I do not know positively, but understand the resident Consul favors the movement and has promised its support. As soon as war is declared, and I guess the news of today is a practical declaration of war, we shall write to the Consul at New York and offer our services. Many of us can and will willingly pay our way back, but the majority will require assistance, which I have no doubt will be furnished by the proper authorities. The Greek colony numbers 3,000 and there are few women and children. If passage money is assured, it is probable 2,000 would embark for Greece without delay.”
Recently, I searched the US Census records to see if I could find Brown. And I did: the 1880 Census lists George Brown, a 40-year-old barber who was born in Greece and living in Chicago. He is listed along with his 26-year-old wife, Louisa, who was born in Italy (which is consistent with his statement in 1888 that he was “married to a Catholic woman”).
The couple also appears in the 1900 Census, along with their children. (The 1890 Census records are unavailable.) Here’s the family:
- George, born in Greece in May 1840, immigrated to America in 1855. He and Louisa had been married for 28 years as of the 1900 Census. This puts their wedding sometime around 1872. George still ran a barbershop in 1900.
- Louisa, born in Italy in June 1855, immigrated to America in 1870. She must have met George not long afterwards, since they were married by 1872 at the latest. The Census reports that Louisa could neither read nor write, although she could speak English.
- Son Leo was born in Illinois in March 1883. His occupation is listed as “Laborer in Grocery.”
- Son Lycurgos (clearly George picked this name) was born in Illinois in June 1884, and in 1900 he worked as an “Errand [boy] in Office.” Incidentally, the early Greek organization in Chicago was known as the “Society of Lycurgos.”
- Daughter Asphasia (or Aspasia) was born in Illinois in May 1890. She’s listed as being “At school.”
- Daughter Consulata was born in Illinois in September 1895.
I can’t find George Brown in the 1910 Census; in fact, I can’t find anyone who even possibly is a match — that is, (1) named George, (2) born in Greece sometime around 1840, and (3) living in Illinois. It’s entirely possible that Brown died between 1900 and 1910. Even in 1900, at age 60, he had surpassed the average lifespan of Americans in his day.
In trying to track down the Brown children, I started with son Lycurgos, for the obvious reason that there can’t be more than one Lycurgos Brown — right? Wrong, actually: In the 1920 Census alone, there were no fewer than six men named Lycurgos (or Lycurgus) Brown. Only one was reasonably close in age to our Lycurgos (who would have been 36 in 1920), but that man, aged 38, was born in Texas, as were his parents. I haven’t been able to find any of the other Brown children in later Censuses, either. However, I found possible matches for daughter Aspasia in the Social Security Death Index. We know that she was born in May 1890, and according to the SSDI, Aspasia Pantek and Aspasia Constantinou were both born in that month. If anyone wants to take the baton and try to track down George Brown’s descendants, go for it — it would be great to see what, if anything, they know about their ancestor.
Finally, further digging turned up the fact that our George Brown’s actual surname was Kotakis. He seems to have dropped it after coming to America. So, here is what we know:
- George Kotakis was born in Greece around 1840.
- He came to America in 1855, took the surname “Brown,” and fought in the Civil War.
- He married an Italian woman named Louisa around 1872.
- He was living in Chicago by at least 1880, and he worked as a barber.
- He was a leader in Chicago’s early Orthodox proto-parish, becoming the community’s president in 1888.
- He had at least four children — two sons and two daughters.
- He may have died between 1900 and 1910.
If anyone out there has any information that can add to our knowledge of George Brown, please email me at mfnamee [at] gmail [dot] com.
[This article was written by Matthew Namee.]
UPDATE: I may have found Lycurgos Brown, George’s second son. On November 16, 1917, a girl named Elizabeth Veronica Brown was born in Cook County, IL (i.e., Chicago). Her birth certificate lists her mother as the former Clara Scanlan, and her father as George Lycurgus Brown, age 33, born in Chicago. Doing the math (1917 minus 33), this man would have been born in 1884 — the same year as our Lycurgos Brown. It’s entirely possible that our Lycurgos actually had the first name of George (after his father), but went by his middle name as a child.
We can verify this hypothesis by revisiting the Census records. In 1910, George L. Brown, a 25-year-old shipping clerk, was living in Chicago with his wife Clara, 3-year-old son George E., and 7-month-old son Daniel P. And according to the Census, George L. Brown’s father was born in Greece, and his mother was from Italy. This is our guy.
I can’t find George Lycurgos Brown in the 1920 Census, but in 1930, he’s still in Chicago. Here is the family:
- George, age 46
- Clara, age 42
- Daniel, age 21
- Gordon, age 17
- Elizabeth, age 12
- Robert, age 5
- Clara G., age 3
- Thomas M., newborn
George Lycurgos Brown’s youngest children would thus be in their eighties today, and it is entirely possible that one or more is still alive. I wonder how much they know about their grandfather, the original George Brown?
UPDATE 2: Sorry for all the updates, but I’ve now traced George Brown’s line down to the present day. Son George Lycurgos Brown’s daughter Elizabeth married a man named Russell Garrett. Elizabeth died in Chicago in 2004, and according to her obituary, her descendants include daughter Elizabeth Balfanz and grandchildren Michael and Rebecca Balfanz.
I’m sure George Brown has dozens of other surviving descendants, through his various other children and grandchildren.
The following item appeared in the Washington Post (among other papers) on July 6, 1933:
Martins Ferry, Ohio, July 5 (A.P.). – The Rev. Parthenios Colonis, 72, pastor of the Martins Ferry Greek Orthodox Catholic Church, died today from hatchet-inflicted wounds. He was found unconscious in the basement of the church Saturday night, his skull fractured by blows from the blunt and sharp edges of a blood-stained hatchet.
He regained consciousness, but did not indicate who attacked him, although police say they believe he knew his assailants. It was the third time in three years that the priest was mysteriously assaulted in his church.
Archimandrite Parthenios Kolonis (or Colonis) born on the Greek island of Patmos in the early 1860s. He was ordained a priest in 1904 and immediately sailed to America, where he went to Milwaukee and established the Church of the Annunciation (Evangelismos). Kolonis served in Milwaukee until 1913; after that, he briefly stopped in Haverhill, Massachusetts before moving to Wheeling, West Virginia, where the founded the parish of St. John the Divine. In 1921, Kolonis made his final move, to Martins Ferry, Ohio, where he reportedly spent a whopping $7,000 of his own money to build the Church of Zoodochos Peghe (the Life-Giving Spring). Finally, as reported above in the Washington Post, Kolonis was brutally murdered in Martins Ferry in 1933.
Apart from his tragic death, Kolonis’ career (on the surface) seems rather ordinary for a Greek priest in early 20th century America. He founded three parishes and spent most of his career in those communities (Milwaukee, Wheeling, and Martins Ferry). He served in numerous other cities as well, among them Pittsburgh, Jacksonville (FL), Pueblo (CO), and Haverhill (MA). All in all, Kolonis had a pretty typical priestly career for his time. Except that he didn’t, because everywhere he went, Fr. Parthenios Kolonis was accused of being a predatory homosexual.
Margot Canaday tells the story of Kolonis in The Straight State: Sexuality and Citizenship in Twentieth-Century America. According to Canaday, Kolonis left Milwaukee under a cloud of scandal. A parishioner had suggested that Kolonis was gay, and Kolonis himself had purportedly written a letter to a boy in Greece, suggesting that the two had engaged in a sexual relationship. Later, an investigation turned up the accusation that Kolonis had sexually assaulted a steward on the ship that brought him to the United States. After leaving Milwaukee, Kolonis moved on to Haverhill, Mass., but he was almost immediately run out of town when multiple young men separately accused the him of sexual misconduct. (I am intentionally not providing all the gory details, but Canaday’s book is pretty explicit about the specific allegations in all of these cases.)
In Wheeling, the problem reached a tipping point. Kolonis purportedly made more advances on young men (including paying money for sexual favors), and eventually news of this reached the US Bureau of Immigration. The Bureau opened an investigation, and they found out about the Milwaukee and Haverhill allegations. In February 1916, the Secretary of Labor issued a warrant for the arrest of Kolonis on the grounds that, being a “moral pervert,” he should have been designated a likely public charge (and thus deported) when he immigrated to the United States in 1904. Kolonis’ attorneys made successful legal arguments in their clients’ favor, and the warrant was rescinded.
But the allegations were still out there. Kolonis argued that he was the victim of an “elaborate blackmail scheme” (Canaday’s description). This seems incredibly unlikely. Kolonis was accused of sexual misconduct literally everywhere he went, by numerous individuals. The accusers in one city seem to have been totally unaware of the allegations in the other cities. We can’t prove anything, certainly not a century after the fact, but I just cannot see how Kolonis could be innocent. (Oddly enough, Canaday’s narrative ends here; she appears to be unaware of Kolonis’ final years and violent end.)
Somehow, Kolonis remained in Wheeling for another five years, even after all the allegations were public. And while I don’t know much about his tenure in Martins Ferry, I think it’s safe to assume that Kolonis was accused there as well. That would certainly explain why he was “mysteriously assaulted in his church” three times in his final three years, and why he apparently knew, but would not identify, his murderer(s). In fact, when Kolonis was discovered by the police, he initially claimed that he had slipped on the basement steps and hit his head on the concrete floor. Dr. Bill Samonides did some digging in local newspapers, and offered the following findings:
According to the Steubenville Herald-Star of July 6, 1933, Fr Colonis died at Martins Ferry Hospital at 12:45 PM. He was attacked the previous night. did not die instantly, but lingered for some hours in the hospital after he was discovered. He is said to have been struck from behind by a hatchet. A skull fracture was assigned as the cause of death. He was struck in the basement of the church. He sustained a head injury in the church the previous Saturday night [July 1]. He told police that he had slipped on the basement steps and struck his head on the concrete floor.
Weirton Daily Times of July 7, 1933 reported that the Martins Ferry Coroner had arrested a Nick George of that town in connection with the murder. Witnesses told the coroner that they had seen George dining with Fr Parthenios the evening of the fatal attack. These witnesses also said that George was the last person seen on the church grounds that day. George was later exonerated and released.
Weirton Daily Times of July 8, 1933 reported that Rev Chrysostomos Papalambrou of Weirton was in charge of the funeral. It seems odd that the Wheeling priest was not in charge.
According to Dr. Samonides, that July 8 Weirton Daily Times article also noted that among Kolonis’ possessions was a painting said to have been owned by Tsar Nicholas II, and valued at a whopping $25,000 (over $400,000 today). I’d love to know what happened to that piece of art after Kolonis died.
We’ve reached the end, and it’s not unreasonable to ask the question, “Why bother telling this horrible story?” The unpleasant reality is that Orthodoxy in America has, today, a serious problem with sexual misconduct among the clergy. It’s a problem that crosses jurisdictional lines, and all ranks of clergymen. The Kolonis story demonstrates that this is, unfortunately, not a new problem for American Orthodoxy. There have always been bad priests who prey on vulnerable people and bring shame upon the Church. Kolonis didn’t really have a bishop (or at least, not one more than an ocean away), so it was easy enough for him to just move to a new city when his deeds started to catch up with him. Today, we don’t have that excuse.
This article was written by Matthew Namee.
In my recent lecture on Orthodoxy in Chicago, given at Holy Apostles Greek Orthodox Church in Westchester, Illinois, I cautiously addressed the still-controversial issue of the 1897 split in Chicago’s Greek Orthodox community. Let me go over the basic details very briefly, before moving onto the broader question of what constitutes a parish.
In 1892, Fr. Panagiotis Phiambolis came to Chicago and founded the city’s first Greek Orthodox church, Annunciation. This community met in a rented space and existed for at least five years. Of that, there is no dispute. In 1897, for various reasons which I won’t get into right now, the parish divided. The Archbishop of Athens had sent Fr. Theodore Papaconstantine to replace Fr. Phiambolis as priest of Annunciation. Fr. Phiambolis refused to step down, and Fr. Papaconstantine led part of the Annunciation community away to start a separate parish, Holy Trinity. Fr. Phiambolis remained in Chicago for a couple of years, until about 1899, after which he moved to Boston.
This is where things get complicated. Some contend that Annunciation closed when Fr. Phiambolis left in 1899 (or even earlier — some date its closure to 1897). These folks say that there was no Annunciation Church in Chicago from then until 1907, when the current parish of Annunciation (now a cathedral) was established. Thus, according to this narrative, there were two Annunciation parishes — we’ll call them Annunciation 1892 and Annunciation 1907.
Others have a different story. They say that while Annunciation did lack a priest from 1899 (or whatever) until 1907, it continued to exist, serviced by visiting priests. At my lecture, a woman in the audience even said that she had a photo from her grandparents’ wedding, taken on the steps of Annunciation’s building in 1902 or thereabouts. A parish can still exist without a resident priest, and the argument here is that the present Annunciation Cathedral is identical to the original Annunciation Church from 1892.
I should also mention a third, related argument, brought up to me by a gentleman after my talk. This man suggested that, actually, Holy Trinity itself, while technically founded in 1897, may reasonably be dated to 1892. After all, the founders of Holy Trinity were all previously members of Annunciation. Holy Trinity could, according to this interpretation, be considered merely a continuation of Annunciation 1892, under a different name.
All of this caused me to take a step back and ask, “What is a parish?” We can say what is definitely a parish — a cohesive community of Orthodox Christians with a permanent place of worship, a resident priest, and regular church services. But beyond that, there’s a huge gray area. I’ve come up with several factors and sub-factors to help define a parish. The list isn’t exhaustive, and you could have a parish with only a couple of these elements.
An Orthodox community. This is the most essential element. On the OCA website, many former Greek Catholic parishes which converted to Orthodoxy date their foundings to the year they were established as Greek Catholic communities. I don’t do that; I would date their foundings as Orthodox parishes to the year when they converted to Orthodoxy. Before that, they may have been parishes, but they weren’t Orthodox.
A cohesive community. In other words, the Orthodox people must think of themselves as being part of a community. You could have 100 Orthodox in a city, and a priest could occasionally visit them, but if they don’t think of themselves as being a community, it’s hard to argue that a parish is present.
A priest. Most normatively, an Orthodox parish has a resident Orthodox priest. However, this element can be satisfied with something less than that. Many missions are serviced by priests who care for multiple churches, or by priests assigned to other parishes. Throughout history, some communities have relied, at times, on the services of itinerant clergy.
Worship space. Again, the norm here would be a permanent Orthodox temple, owned by the parish. Alternatively, a parish might rent its building. This could be broken down further — the parish could rent the building every day of the week, or only on certain days (e.g. Sundays).
Regular church services. The basic standard is a Sunday liturgy each week, but of course many parishes do a lot more than that. However, you could have a parish that meets less often (only once or twice per month). And while priest-led services are the norm, in theory, regular meetings of the laity for prayers might suffice.
Incorporation. Most parishes are incorporated as legal entities with the state. However, it’s also true that parishes usually predate their incorporation. After all, until you have at least some of the basic elements of a parish, how could you take the steps to incorporate? Incorporation helps us identify a parish, but lack of incorporation doesn’t mean there isn’t a parish.
A parish council or board of trustees. This isn’t absolutely essential, but it’s the norm for Orthodox parishes in America.
Hierarchical oversight. Today, to be an Orthodox parish in America, you pretty much have to be under a bishop. That wasn’t always necessarily the case. I mean, I guess you could argue that some of the early American Orthodox parishes weren’t really Orthodox, because they were established in an ecclesiologically irregular manner, but I don’t take that approach myself. At the very least, there usually was some minimal tie to a bishop or “mother church.”
A common name: Having a common name doesn’t mean a community is a parish, but you’d be hard-pressed to find a parish that didn’t have a name along the lines of “Annunciation,” “Holy Trinity,” or “St. Nicholas.” I’ve heard of fledgling missions called, “Orthodox Mission of [City],” but they usually get a name pretty soon after their establishment.
Self-identity as a parish. This is actually kind of a big one. In Chicago, prior to the 1892 founding of Greek and Russian parishes, the city had a cohesive community of Orthodox Christians. These people had organized themselves into a “society” for the purpose of starting a parish. They elected officers. They seem to have had a name (St. Nicholas), may have rented worship space, and may have had something resembling regular services. Yet, they clearly didn’t consider themselves a parish. In 1888, they met to decide whether to start a parish, and as late as 1892, there was still talk of starting a multiethnic parish. They obviously didn’t consider themselves to be a parish, even though they had a lot of the fundamental elements. In some cases, we might look back with hindsight and say, “That was a parish,” even if the community didn’t say so at the time. But the burden of proof is higher, I think.
In sum, then, we can say for certain that an Orthodox parish exists if there is a cohesive Orthodox community with a common name, self-identifying as a parish, under the jurisdiction of a bishop, incorporated with the state, with a board of trustees, and holding regular church services with a resident priest in a permanent worship space. But lots and lots of parishes don’t have one or more of those elements, and they’re still indisputably parishes.
I think the mimimum to call something a parish has to be a cohesive Orthodox community, but even that may not be enough. Consider: I was once a part of a cohesive Orthodox community which held regular services in a permanent worship space, led by a resident and full-time Orthodox priest. We had a name, a patron saint. We didn’t self-identify as a parish, and while our priest was under an Orthodox bishop, our community was technically an OCF (Orthodox Christian Fellowship, a campus ministry) not under any one hierarch. We didn’t self-identify as a parish; we called ourselves an OCF, even though we had many regular worshippers who weren’t actually OCF members. Later, our priest left his jurisdiction for another, and our community was converted into a mission parish under a specific bishop. At that point, we incorporated ourselves and elected a parish council. Were we a parish at the beginning, when we self-identified as merely an OCF? I don’t think we were, but looking back, it wouldn’t be unreasonable for someone to say, “Hey, that’s a parish, whether you say it is or not.”
Another interesting question, this one from history, concerns the original Orthodox community in Portland, Oregon. In the 1890s, an Orthodox chapel called Holy Trinity was established in Portland, under the oversight of the Russian Diocese. The community had a permanent building and was served by priests who visited from the larger Orthodox parish in Seattle. The Russian Diocese, and perhaps the local community, referred to it as a “chapel.” Was this a “parish,” or was it something else — to steal a term from others, a “proto-parish”? Later, the Greeks formed their own parish, which was also called “Holy Trinity” and, at the outset, rented the original Holy Trinity chapel building. This raises another question: was Holy Trinity Greek parish a continuation of Holy Trinity Russian chapel? After all, at least some (and perhaps most) of the Holy Trinity Greek founders had previously attended Holy Trinity Russian chapel. It’s a gray area.
Returning to the original issue: did Annunciation parish of Chicago persist during the early 1900s, or did it close? Put another way, was the present Annunciation founded in 1892, or 1907? There is, I’m afraid, no single answer. Let’s do the analysis:
- An Orthodox community: The key question here is whether there were Greek Orthodox people in Chicago who weren’t members of Holy Trinity. I think the answer is yes.
- A cohesive community: Again, I think the non-Holy Trinity Greeks continued to exist as a cohesive community, as evidenced by the existence (or founding) of Annunciation in 1907.
- A priest: No, there was not a resident Greek priest in Chicago apart from Holy Trinity in the gap period.
- Worship space: I think the original Annunciation worship space continued to be maintained. I haven’t verified this, but if true, it is a key argument in favor of Annunciation’s claim.
- Regular church services: I don’t think there were regular services. I’ve heard that visiting priests occasionally held services for the Annunciation survivors.
- Incorporation: I’m not sure, but I don’t think the community was incorporated prior to 1907. I hope readers will correct me if I’m wrong.
- Board of trustees: I don’t know about this. I strongly suspect that there continued to be officers, but I don’t know for sure. This would be another good argument that there was a parish.
- Hierarchical oversight: Bishops had little practical oversight of Greek parishes in America at the turn of the last century, and without a resident priest, I can’t imagine the Annunciation survivors had much contact with a hierarch.
- A common name: The argument here depends a lot on this element. The claim is that Annunciation’s survivors continued to refer to themselves as “Annunciation” during the gap period.
- Self-identity as a parish: This is another critical element, and Annunciation partisans would certainly argue that this self-identity existed.
This leaves us with some basic questions, and perhaps someone in Chicago could look into them:
- Did Annunciation’s building continue to be maintained and used by a Greek Orthodox community?
- Were the members of that community not members of another Orthodox parish (i.e. Holy Trinity)?
- Did that community have a board of trustees?
- How often did the community meet for services? How often did a priest visit them? (One place to start looking would be state marriage records.)
- Did the parishioners in 1907 understand themselves to be (re-)founding the parish, or did they think that the parish had continued to exist during the gap?
We’ll continue to explore the issues of parish identity in the future, but the whole Chicago debate reminds me that we must always ensure that we define our terms. We can’t take for granted that we all know what a “parish” is, because, as I think I’ve demonstrated, there’s a lot more gray area than we might initially assume.
This article was written by Matthew Namee.