L & L Associates Holding Corp. v. Charity United Baptist Church

OPINION OF THE COURT

Michael A. Ciaffa, J.

When Martin Luther posted his “Ninety-Five Theses on the Power and Efficacy of Indulgences” on the door of Castle Church in Wittenburg on the eve of All Saints Day, October 31, 1517, he also sent a copy to the Archbishop who was responsible for the sale of indulgences. In that manner, he gave actual notice of his grievances to responsible church officials.

This nonpayment eviction proceeding against an unincorporated church presents, as one of its issues, whether a landlord must provide similar actual notice to church officials in order to secure a…