Chih-Chen Ma et al. v. Wei Li Wang; Ming Tong a/k/a Ming Tung; and China Buddhist Association
Attorneys and Parties
Brief Summary
Religious nonprofit corporate governance and leadership succession under bylaws; applicability of the ecclesiastical abstention doctrine.
Denied a preliminary injunction preventing Wei Li Wang from acting or holding herself out as Grandmaster/officer/trustee of China Buddhist Association (CBA); later held plaintiffs in civil contempt for violating a January 14, 2025 order enforcing a December 5, 2022 board resolution.
The denial of the preliminary injunction was modified—an injunction was granted barring Wang from holding herself out as Grandmaster/officer/trustee pending an election under Article 13 of the bylaws; the civil contempt order was affirmed.
The ecclesiastical abstention doctrine did not apply because Article 13 of the bylaws provided a neutral, secular process requiring member and trustee approval for succession; plaintiffs showed likelihood of success, irreparable harm (loss of control), and equities favoring preservation of the status quo. Challenges under Religious Corporations Law (RCL) § 5 [precludes a religious corporation's trustees from removing a religious leader and requires adherence to bylaws] and RCL § 195 [does not expressly preclude adoption of a more robust voting threshold in bylaws] were unavailing; objections to the amendment adding Article 13 were unsupported.
Background
A leadership dispute arose at China Buddhist Association (CBA) after defendant Wei Li Wang assumed the role of Grandmaster without a confirming vote by CBA’s members and trustees as required by Article 13 of the bylaws. Plaintiffs sought a preliminary injunction to prevent Wang from acting or holding herself out as Grandmaster/officer/trustee pending an election. Separately, after a December 5, 2022 board resolution governed interim access and management, the Supreme Court issued a January 14, 2025 order directing the parties to abide by that resolution until the next election.
Lower Court Decision
Supreme Court (New York County) denied plaintiffs’ motion for a preliminary injunction and later, on June 2, 2025, held plaintiffs in civil contempt for violating the January 14, 2025 order by refusing Wang access to books, records, and bank accounts as provided in the December 5, 2022 board resolution.
Appellate Division Reversal
The Appellate Division modified the December 20, 2024 order to grant a preliminary injunction consistent with the court’s March 13, 2025 order: Wang is enjoined from holding herself out as Grandmaster, officer, or trustee of CBA pending an election conducted under Article 13 of the bylaws, and the officers and trustees are to control day-to-day management until the election. The June 2, 2025 contempt order was affirmed, including the directive that plaintiffs provide Wang with an operable key for access to her home.
Legal Significance
Reaffirms the neutral-principles approach to religious corporation disputes: courts may enforce corporate bylaws to resolve leadership succession without delving into doctrine. Confirms that RCL § 5 [precludes trustee removal of religious leaders and requires adherence to bylaws] and RCL § 195 [does not expressly preclude stricter bylaw voting thresholds] do not bar a bylaw-mandated membership/trustee vote for leadership succession. Confirms loss of corporate control as irreparable harm and emphasizes strict compliance with clear court orders to avoid contempt.
When bylaws prescribe a neutral process for selecting religious leaders, courts can enjoin self-appointment and require an election; failure to obey unequivocal interim court orders supports civil contempt.