Tenth Presbyterian Church v. Snyder, P.

CourtSuperior Court of Pennsylvania
DecidedMay 31, 2024
Docket1321 EDA 2023
StatusUnpublished

This text of Tenth Presbyterian Church v. Snyder, P. (Tenth Presbyterian Church v. Snyder, P.) is published on Counsel Stack Legal Research, covering Superior Court of Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Tenth Presbyterian Church v. Snyder, P., (Pa. Ct. App. 2024).

Opinion

J-S04044-24

NON-PRECEDENTIAL DECISION - SEE SUPERIOR COURT O.P. 65.37

TENTH PRESBYTERIAN CHURCH : IN THE SUPERIOR COURT OF : PENNSYLVANIA : v. : : : PHILIP SNYDER : : Appellant : No. 1321 EDA 2023

Appeal from the Order Entered April 18, 2023 In the Court of Common Pleas of Philadelphia County Civil Division at No(s): 190703016

BEFORE: BOWES, J., STABILE, J., and LANE, J.

MEMORANDUM BY LANE, J.: FILED MAY 31, 2024

Philip Snyder (“Snyder”) appeals from the order granting the emergency

motion for injunctive relief for a preliminary injunction filed by Tenth

Presbyterian Church (“the Church”). We affirm in part, vacate in part, and

remand for further proceedings.

This matter has been before this Court in three prior appeals. In one of

those appeals, this Court summarized the factual and procedural history of

this dispute as follows:

The Church owns several properties in Philadelphia. The Church’s primary facility is located at 1701 Delancey Street (“the Property”). Snyder moved to Philadelphia in 2008, after which he joined the Church, where he remained a member until the Church excommunicated [him] in August 2016. Snyder thereafter began picketing at the Property regarding his excommunication and the conduct of certain current and prior Church officials. Snyder brought a defamation action against individual members of the Church, but ultimately, a jury tendered a verdict against Snyder. J-S04044-24

After the verdict in the defamation action, Snyder protested outside of the Property every Sunday, before and after Church services. [In] 2019, the Church filed a complaint for an injunction and an emergency motion for injunctive relief for a preliminary injunction. The Church sought to restrict Snyder from coming within 1,000 feet of all properties owned by the Church. Following oral argument, Snyder temporarily agreed to the Church’s requested relief.

The trial court subsequently conducted a hearing on the Church’s motion for a preliminary injunction [i]n . . . 2020. The trial court described the evidence presented at that hearing as follows:

Snyder testified that he began picketing outside of the Property after the . . . 2019. . . jury verdict more frequently, with a sign that contained the phrase “naked beatings,” “lying,” and “rape,” because he was displeased with the results of the case. Snyder further testified that he had protested while wearing a body camera and filmed congregants outside of the Property. Snyder testified that a trial court order and subsequent opinion in the defamation case misrepresented the truth. Douglas Baker (Baker), the Church’s former administrator, testified that Snyder frequently wore a visibly “concealed” firearm to church services when he was a member, and that he continued the practice while picketing with the sign and body camera. Baker testified that Snyder would verbally harass and yell at congregants outside the Property and then post body camera videos on a blog. Dr. William Goligher (Dr. Goligher), senior minister for the Church, testified that Snyder called him the “son of Satan” and a liar. Dr. Goligher testified that Snyder had verbally disparaged Snyder’s own family for not committing to his protest and not being faithful, including referring to Snyder’s wife as Job’s wife . . . Dr. Goligher also testified that Snyder seemed preoccupied with safety and firearms, such that he would stand beside Dr. Goligher and point out individuals whom he thought were carrying firearms. Snyder’s fixation on security and policing, even minor behaviors of the Church congregants, went on for years and included concerns about stolen phones,

-2- J-S04044-24

money, and immigrants. Snyder himself provided testimony that he has been the only individual telling the truth, that he has mailed 100 pages of material to 200 members of the Church, that he will never stop any of his behaviors until the Church’s leadership has resigned in full, and that the Church was trying to poison him and hire a hitman to assassinate him. Susan Elzey (Ms. Elzey), a congregant, testified that outside of Church services [in] 2019, Snyder told her he was an instrument of God, similar to a prophet, and that only Snyder knows the true nature of Dr. Goligher’s soul. Snyder went on to tell Ms. Elzey that Dr. Goligher was a son of Satan, and that any congregants who support Dr. Goligher are doing Satan’s work. Snyder also told Ms. Elzey that he was unhappy with his wife, described her as Job’s wife because she did not support him, and that his oath to remove Dr. Goligher from the Church was more important to him than his family.

By order dated February 10, 2020, the trial court granted the Church’s motion and enjoined Snyder from appearing within five thousand (5,000) feet of the Church’s properties located at (1) 1701 Delancey Street; (2) 1700 Spruce Street; (3) 315 S. 17th Street; (4) 1710 Spruce Street; and (5) 1716 Spruce Street.

Trial Court Opinion, 8/21/20, at 1-5 . . ..

Tenth Presbyterian Church v. Snyder, 266 A.3d 640 (Pa. Super. 2021)

(unpublished memorandum at **1-5) (emphasis, brackets, unnecessary

capitalization, and some quotation marks omitted).

In an appeal of the February 2020 order granting the Church’s motion,

this Court affirmed the trial court’s determination that a preliminary injunction

was warranted; however, based on the Church’s request for a 1,000 feet

restriction, this Court reversed the imposition of a 5,000-foot restriction

-3- J-S04044-24

against Snyder, and remanded for the trial court to fashion a distance

limitation that was sufficient to protect congregants’ access to the Church and

its services, yet continued to uphold Snyder’s constitutional right to convey

his dissatisfaction with the Church and its leadership. See id. (unpublished

memorandum at **24-25). This Court directed the trial court to narrowly

tailor the injunction to “address the physical realities of each Church property

. . ..” Id. (unpublished memorandum at *22 n.3). Upon remand, the trial

court entered an order granting the Church’s motion and enjoining Snyder

from appearing within 1,000 feet of all Church-owned properties; however, it

did not address the physical realities of each Church property.

The matter returned to this Court on an appeal from that order. This

Court noted that the order did not indicate that the trial court had weighed

the physical characteristics of each Church property and tailed the distance

limitation accordingly. As such, this Court affirmed all aspects of the order

except for the 1,000 feet distance limitation, which was vacated. This Court

acknowledged the trial court’s finding that Snyder engaged in aggressive and

agitated behavior that frightened Church members inside and outside of the

Property, but directed the trial court to explain upon remand why its distance

restriction of 1,000 feet was the least necessary distance to protect Church

property, permit the congregants and Church employees access to the Church

and to hold services without distraction, with the least possible impingement

on Snyder’s constitutional right to convey his dissatisfaction with the Church

-4- J-S04044-24

and its leadership on public streets and sidewalks. See Tenth Presbyterian

Church v. Snyder, 285 A.3d 917 (Pa. Super. 2022) (unpublished

memorandum at *12). On remand, the trial court entered an order in granting

the Church’s motion and enjoining Snyder from appearing within 500 feet of

all Church-owned properties.

On appeal of that order, this Court determined that the trial court’s

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Bluebook (online)
Tenth Presbyterian Church v. Snyder, P., Counsel Stack Legal Research, https://law.counselstack.com/opinion/tenth-presbyterian-church-v-snyder-p-pasuperct-2024.