DAVID E. ROBINSON, et al, pro se______________________
Plaintiff
v.
CHRISTIAN SCIENCE BOARD OF DIRECTORS, et al______
Defendants

1. The issues of life under a democratic government lie largely with the individual. No form of government interferes less with individual development here on earth than a true democracy.

2. To the Christian Scientist, the ultimate goal of all endeavor is to rise above the claims of human existence into the atmosphere of Mind.

3. No human laws, no legislative bodies, no police, no navies, nor armies will be required in a state where Mind alone rules. But until such a state is humanly achieved, some type of government seems to be necessary in both secular and church affairs.

4. Mrs. Eddy established the government of the branch churches entirely in accord with democratic principles. The government of the material Mother Church, however, is not a democratic one. Its government is not obtained with the consent of the governed. Its participants have no part in selecting the highest officers in the church, for the four member Board of Trustee-Directors is a self-perpetuating Board.

5. Provision has been made through the 1892 Deed of Trust to continue services in the Church where the congregation is styled The First Church of Christ, Scientist, in Boston, Massachusetts, but not in regard to Mother Church.

6. While The First Church of Christ, Scientist, in Boston, Massachusetts, may carry on for an indefinite period of time, there is still a definite provision in the Deed of Trust that services may ultimately be discontinued, for "whenever said [Director-Trustees] shall determine that it is expedient to cease to maintain preaching, reading or speaking in said church in accordance with the terms of this deed, they are authorized and required to reconvey forthwith said lot of land with the building thereon to Mary Baker Eddy, her heirs and assigns forever by a proper deed of conveyance."

7. The Board now known as the Christian Science Board of Directors -- the five member one operating under the Manual of the Mother Church -- is not the Board of Trustee-Directors named in the 1892 Deed of Trust.

8. The Board of Directors of five members named in the Manual requiring Mrs. Eddy's written consent for its continuance should have voted to dissolve itself in June 1911 if it had acted in obedience to Mrs. Eddy's Manual instructions.

9. Since the Annual Meeting of the Mother Church for the election of officers for one year is held each June, no elections should have been held later than that date in accord with the By-laws requiring Mrs. Eddy's consent.

10. On the other hand, the Board appointed under the 1892 Deed of Trust is composed of four members only instead of the five now serving in the Mother Church. This Board of four members is empowered under the Deed of Trust to discontinue services in the Extension of the Mother Church whenever they consider it expedient to do so, and they are so empowered without recourse or advice from any other person or body.

11. The government of this Deed of Trust Church, "The First Church of Christ, Scientist, in Boston, Massachusetts," is not a democratic government any more than is the government of the present Mother Church. It
is being governed by the four member Board without recourse. In fact no provision has been made for this Church of
Christ, Scientist, to have members after the pattern of the branch churches, for no membership is provided for in the
1892 Trust Deed, consequently all necessary rules and regulations for the conduct of the church are made by the four member board appointed under the Deed of Trust.

12. Should this board determine it inexpedient to carry on services in The First Church of Christ, Scientist, it could cease to do so.

13. It must be assumed that Mrs. Eddy foresaw the possibility that the time would come someday when The First Church of Christ, Scientist should also be dissolved; for Section 10 of the 1892 Deed of Trust states that "whenever. the Directors shall determine it inexpedient to continue services, they shall be discontinued. This seems to infer that Mrs. Eddy not only considered it possible, but probable, that such an event would someday take place.

14. It seems obvious that Mrs. Eddy did not look upon the material Mother Church and The First Church of Christ, Scientist, as organizations after which all future organizations should pattern themselves, or she would not have established both subject to dissolution; the one through her passing and the other at the discretion of the four Directors.

15. On the other hand, nowhere in the Manual does Mrs. Eddy provide that the other churches in the Field should ever be discontinued. Only the churches that are hierarchical in form of government are marked for termination.

16. Mrs. Eddy established the Branch Church in Concord, New Hampshire as the pattern for the branches of the world.

17. The democratic government exemplified in the branches is evidently meant to be carried on for an indefinite time, or until such government has been superseded by a higher and more spiritual form not yet discerned.

18. The true spiritual Mother Church, "the structure of Trust and Love," is a mental concept that can never be dissolved.

19. Salvation is not to be achieved by organization but by emancipation from organization for organization retards spiritual growth. Whatever hastens that emancipation, therefore, benefits the human race. Whatever retards it is to be put off.

20 Despotic control is inherent in human government, and while at its inception, despotism may not show itself in its true colors, the seed is sown the very instant central government is established and the chaff of despotism grows along with the wheat of democracy. It has happened over and over again. It is almost inevitable in human history.

21. There are signs in the world today of a tremendous attack upon democracy. In some quarters it is an outside attack of a totalitarian state upon its democratic neighbors. In other quarters it is a trend within the government itself, an indication that the subtle foe is at work from within.

22. The growth of such a trend within either church or secular government cannot always be laid to wrong motives. Too often the motives are the highest but the subtle influence of acquired power sways men's reason and democracy succumbs to despotism.

23. No one will affirm that the motive of the Defendants is or has been wrong. The Defendants have undoubtedly convinced themselves that the growth of Christian Scientists all over the world is vastly accelerated by the Board's policing of their reading matter. It is a subtle influence that deprives the individual of complete dominion over his own thoughts.

24. It should be the aim of every individual to be wholly guided by the divine Mind in every aspect of life. And in proportion as we are thus guided we live a harmonious and ever expanding existence and benefit every one with whom we come in contact.

25. To a Christian Scientist, independence of thought is absolutely essential in order to be directed by God. To allow others to make his decisions for him, or to even confer such power upon another voluntarily, is an exceedingly dangerous thing to do, for it is only by complete subjection of his own will to the divine Will that complete emancipation from the material world can be accomplished. To the degree that we hear the voice of Truth, we cannot hear the voice of the carnal mind.

26. The conclusion is incontrovertible. Freedom lies in complete independence of thought and action; despotism gains power when we yield our thoughts and acts to another's will.

27. It is when problems seem to become complex that the human mind is baffled. The more complex the problems grow to be, the more puzzling and difficult the solution seems to be.

28. The temptation to let others do our thinking for us is even great in minor affairs. But when the majority in government yield to that temptation the seed of despotism is sown.

29. When out forefathers came to America social life was relatively simple. Communication was confined mainly to individuals and communities in close proximity. Whatever diversity of interests might arise were confined within such narrow limits and to so few persons that they were easily reconciled.

30. Such delegation of responsibility may seem beneficial in the beginning, but too often it leads to an assumption of more and more power by the one on whom reliance has been placed, and the seed of despotism and greed which eventually leads to war takes root.

31. In the early stages of Hitler's rise to power in Germany the economic situation seemed difficult and complex. Hitler offered a solution which the German people accepted. They yielded the right of government to him and he gradually seized more and more power until he dominated all German national existence.

32. The people permitted the presumed Directors of the Mother Church, lttle by little, to gain control over the right of speech and self-expression, until they were unable to express themselves in dissent without being subject to punishment meted out by the Directors upon themselves. Had the very first despotic encroachments made upon church participants been thwarted, this lawsuit might have been avoided.

33. It is not easy to dislodge mortal mind when it has become entrenched. The time to dislodge it is when it first seems to appear if we would save ourselves the suffering that inevitably is its result.

34. The very impulse to allow an ecclesiastical body to prescribe our reading or censor speech is nothing short of aggressive mental suggestion. It is the first false move leading to despotic control.

35. It is the purpose of mortal mind to control others by depriving them of their dominion. Since it has no dominion of its own, mortal mind gets what dominion it seems to have by stealing it from its victims.

36. Yet since 1910, the seeming power of intimidation has so permeated churches and individual thought in the Field, that a belief in the omniscience of the authorities in Boston has become almost a fetish; and their decisions are largely accepted without question or thought.

37. Mrs. Eddy governed the organization and was the final word in its operation by virtue of the fact that she had conceived it, organized it and put it into operation. She was as much a directing head as the owner of any business.

38. The Directors in 1910 appointed themselves to be Mrs. Eddy's successors even though their act violated Mrs. Eddy's instructions given in the By-laws of the Manual and the Deeds of Trust.

39. The decision was made and adopted, with weapons of the carnal mind used to maintain their stand. They fought the opposition, not with demonstration, but with interdictions and penalties. More and more punishments are being meted out today by the Board of Directors at Boston. Many of these penalties imposed by the Board not only violate Christian principles, but the fundamental rights conferred upon every citizen of the United States by the Bill of Rights supplementing the Constitution of the United States of America.

40. Article VI of the Bill of Rights states that the accused shall enjoy the right "to be confronted with the witness against him." Such a statute not only accords with simple justice but is indigenous to democracy itself. Mrs. Eddy has incorporated this principle of jurisprudence in the Manual of the Mother Church in a literal quotation from the Bible, in the words of Jesus himself, at Manual, Article XI, Section 2:

"A member who is found violating any of the By-laws or Rules herein set forth, shall be admonished in consonance with the scriptural demand in Matthew 18:15-17": -- "Moreover if thy brother shall trespass against thee, go and tell him his fault between thee and him alone: if he shall hear thee, thou hast gained thy brother. But if he will not hear thee then take with thee one or two more, that in the mouth of two or three witnesses every word may be established. And if he shall neglect to hear them, tell it unto the church."

41. The Defendants have openly declared that "this scriptural passage does not apply to them."

42. The underlying cause, in a sense, belongs to the Field for it is a serious error for the Field to leave these acts unchallenged. It has a Manual duty that should not be deferred, for the roots of despotism sink deeper and deeper when undisturbed.

43. In their zeal to protect the truth the Defendants violate the very truth that they are so zealous to protect, by invading the inherent right bestowed upon every individual in a democracy to exercise their independence of thought and action.

44. Since individuals are restrained by a system of punishments, such a government can be corrected only by united action. This action rarely comes, however, until the acts of government become so overt that the mass of those so governed are roused to rebellion and the offending government is displaced.

"Prudence, indeed, will dictate that Governments long established should not be changed for light and transient Causes; and accordingly all Experience hath shown, that Mankind are more disposed to suffer, while Evils are sufferable, than to right themselves by abolishing the Forms to which they are accustomed. But when a long train of Abuses and Usurpations, pursuing invariable the same Object, evidence a Design to reduce them to absolute Despotism, it is their Right, it is their Duty, to throw off such Government, and to provide new Guards for their future Security." (Preamble to the Declaration of Independence of 1776).

46. Force is not the way of spiritually minded Christians. We do not right our wrongs that way. But when continued usurpation of individual rights (and breaches of Last Wills and Testaments and real estate Deeds of Trust) evidence a trend toward autocratic control and human directives, it is not alone our right, but our solemn duty to search out the causes and rise in protest against them.

47. The Plaintiff hereby stands and rests upon the record of his complaint.