Christian Congregation of Jehovah’s Witnesses v. Township of Gloucester

CourtDistrict Court, D. New Jersey
DecidedApril 1, 2026
Docket1:25-cv-01459
StatusUnknown

This text of Christian Congregation of Jehovah’s Witnesses v. Township of Gloucester (Christian Congregation of Jehovah’s Witnesses v. Township of Gloucester) is published on Counsel Stack Legal Research, covering District Court, D. New Jersey primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Christian Congregation of Jehovah’s Witnesses v. Township of Gloucester, (D.N.J. 2026).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY

CHRISTIAN CONGREGATION OF JEHOVAH’S WITNESSES, No. 25-cv-01459 Plaintiff,

v. OPINION

THE TOWNSHIP OF GLOUCESTER,

Defendant.

APPEARANCES:

Dylan Lamorte Joseph Sine COHEN SEGLIAS PALLAS GREENHALL & FURMAN 1600 Market Street 32nd Floor Philadelphia, PA 19103

On behalf of Plaintiff.

Vincent P. Sarubbi Christopher Terlingo James Michael Graziano ARCHER AND GREINER 1025 Laurel Oak Road Voorhees, NJ 08043

On behalf of Defendant. O’HEARN, District Judge. This matter comes before the Court on Defendant Township of Gloucester’s (“Defendant” or “Township”) Motion to Dismiss Plaintiff Christian Congregation of Jehovah’s Witnesses’ (“Plaintiff” or “CCJW”) Amended Complaint for lack of subject matter jurisdiction under Federal Rule of Civil Procedure 12(b)(1) and failure to state a claim under Rule 12(b)(6). (ECF No. 16). The Court heard oral argument on November 21, 2025. For the reasons that follow, Defendant’s

Motion is GRANTED. I. FACTUAL BACKGROUND The following facts are taken from Plaintiff’s Amended Complaint, (ECF No. 24), which the Court accepts as true for purposes of this motion. CCJW is a non-profit religious organization that owns the Turnersville Assembly Hall (“Hall”) of Jehovah’s Witnesses in Blackwood, NJ. (Id. at ¶¶ 2–3). CCJW alleges that the property “has been declared tax-exempt from local real estate taxes pursuant to the Constitution of New Jersey and New Jersey statutes.” (Id. at ¶ 3).1 The Hall was developed by CCJW’s predecessor, Jehovah’s Witnesses of Southern New Jersey, Inc. (“JWSNJ”) in the 1990s.2 (Id. at ¶¶ 16–20). It serves as an integral place of worship and assemblage for religious purposes. (Id. at ¶ 4).

1 It is unclear to the Court precisely what CCJW alleges in this paragraph of the Amended Complaint, as surely if there was a judicial or other binding determination as to the tax-exempt status of the property there would be no dispute between the parties. The Court presumes CCJW is merely characterizing the Township’s prior treatment of the property as tax-exempt in its records and as declared in the PILOT Agreement, as discussed elsewhere in the Amended Complaint, as a de facto determination of the tax-exempt status of the property.

2 In June 2008, title to the property was transferred from JWSNJ to Jehovah’s Witnesses Assembly Halls of New Jersey, Inc. (“JWAH”). (Id. at ¶ 30.) In April 2023, CCJW merged with JWAH and became the owner of the property. (Id. at ¶ 37.) 2 During the development of the Hall, JWSNJ and the Township entered into a payment-in- lieu-of-taxes agreement (“PILOT Agreement” or “Agreement”) on March 15, 1999. (Id. at ¶ 20; Ex. 1, ECF No. 24-1). The PILOT Agreement acknowledged that JWSNJ was a tax-exempt religious entity and that its property used for religious purposes would “ordinarily be exempt from real estate taxes.” (Am. Compl., ECF No. 24 at ¶ 22). Nevertheless, JWSNJ agreed to make a “contribution in lieu of local purpose taxes that would have been generated if the Property (as

developed) had been subject to local taxation.” (Id. at ¶ 23). The Township’s Tax Assessor would determine the value which “would have been established as the assessed value” had the Hall been subject to taxes using the “usual and normal methods for evaluating property taxes.” (Ex. 1, ECF No. 24-1 at ¶ 2). JWSNJ agreed that it would make these contribution payments for each year that the Hall was exempt from real property taxes. (Am. Compl., ECF No. 24 at ¶ 24). The Township in turn agreed that it would not “seek to assess or levy any real estate taxes or other payments in lieu of taxes” while the Agreement was in effect. (Id. at ¶ 25). The Agreement did not include an express end date or termination provision; instead CCJW alleges the Township retained the unilateral right to cancel the Agreement by seeking to assess or levy real estate taxes. (Id. at ¶ 26). CCJW is the only religious entity that is subject to such an arrangement with the Township. (Id. at

¶ 50). It further alleges that the Township had no statutory authority to enter into the Agreement. (Id. at ¶¶ 48–49). Since 1993, CCJW and its predecessors have paid more than $1.3 million under the Agreement. (Id. at ¶ 52). Over time, the Township increased the payments from about $30,000 annually in 2000 to about $80,000 by 2010. (Id. at ¶ 31). CCJW’s predecessor repeatedly sought to modify or terminate the Agreement, but, in 2019, the Township refused to do so. (Id. at ¶¶ 32– 3 35). On February 13, 2023, the Township sent a letter demanding payment of $52,640 for the 2023 tax year under the Agreement. (Id. at ¶ 36; Ex. 4, ECF No. 24-4). On December 19, 2023, the Township sent a delinquency notice stating that CCJW “must pay ASAP or your abatement will be removed.” (Am. Compl., ECF No. 24 at ¶ 38). The Township then sent another delinquency letter on March 21, 2024, after CCJW sent a letter to the Mayor stating its intention to no longer make payments under the Agreement. (Id. at

¶ 39). The Township claimed that the Hall was not a church and that CCJW was in breach of the Agreement and in default for failure to make payments for two or three prior quarters, thereby making CCJW “subject to a regular tax assessment under the laws of the State of New Jersey.” (Id. at ¶ 40).3 On July 2, 2024, the Township sent a notice to CCJW advising that it was in default for nonpayment and “threatened” to impose full property taxes of $173,383 for 2023 and $86,691.50 for the first half of 2024, plus interest and penalties. (Id. at ¶ 42). The Township has publicly listed a delinquency and outstanding principal amount owed by CCJW in the amount of $26,320.00 on its website. (Id. at ¶ 45). However, the Township’s records continue to show the Hall as benefitting from a tax exemption based on its status as “Church/Charitable.” (Id. at ¶ 46). CCJW asserts that the Township’s efforts to “challenge its tax-exempt status” and impose

“exorbitant and outstanding fees” amount to “discriminatory and punitive treatment.” (Id. at ¶ 61). It further asserts that the Township has intentionally discriminated against it on the basis of religion because it is the only religious entity subject to a PILOT Agreement and that other churches operate

3 The attached exhibit indicates that the Township conducted a review of the “historical facts that resulted in the PILOT Agreement.” (Ex. 7, ECF No. 24-7). That review determined that the Hall required zoning changes and that the “structure Improvement is not a church” thus making it “subject to local property taxation” in the absence of the PILOT Agreement. (Id.). 4 tax-exempt properties that are similar to the Hall in all relevant respects and are not subject to a PILOT Agreement. (Id. at ¶¶ 56, 62–67). CCJW claims that it has suffered harm as it has been forced to divert funds to make payments under the Agreement. (Id. at ¶ 43). It is also “immediately threatened with harm as a direct result” of the Township’s “actions to tax it as if it was a taxable entity.” (Id. at ¶ 74). At oral argument, CCJW confirmed that it has not made any payments under the Agreement for approximately two years. (Tr. at 15).

II. PROCEDURAL HISTORY CCJW filed its Complaint on February 25, 2025. (ECF No. 1). The Township filed its Motion to Dismiss on April 30, 2025. (ECF No. 16). After briefing, the Court heard oral argument on November 21, 2025.4 After argument, the Court administratively terminated the Motion to Dismiss, granted CCJW leave to file an Amended Complaint, and ordered the parties to file supplemental briefing to more fully address: 1) whether the Court should abstain from deciding the case under the comity doctrine and 2) whether the claims are fully ripe for adjudication. (ECF Nos. 22–23).

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Christian Congregation of Jehovah’s Witnesses v. Township of Gloucester, Counsel Stack Legal Research, https://law.counselstack.com/opinion/christian-congregation-of-jehovahs-witnesses-v-township-of-gloucester-njd-2026.