1. The Supreme Judicial Court of the Commonwealth has ruled on Church polity in several cases, including Weaver V. Wood, Dittemore V. Dickey, and Eustace V. Dickey.

2. In each of these cases, the Court seriously misstated Church polity, due to the Directors' fraud on the courts and the oversight or omission of significant documents, and to the degree that these decisions express erroneous conclusions regarding Church organizational structure, they should be set aside.

3. The Court originally misconstrued Church polity in Eustace v. Dickey. The Court confused the two Boards of Directors, in assuming that the manual By-law which added a fifth Director in February, 1903, changed the number of Directors from the four identified in the 1892 Deed of Trust.

4. The Court explained: "There was no rule fixing their number until February, 1903, when a by-law was adopted, which has since continued in force establishing their number at five." That by-law should not, however, have continued in force following Mrs. Eddy's demise in 1910, and it was not a rule fixing the number of Directors beyond that occurrence, because it specifically required Mrs. Eddy's approval for the appointment of Directors.

4. The Eustace court also operated under the mistaken assumption that, following abolition of the First Members, Mrs. Eddy gave all power to the directors, that "the entire management...passed into the hands of the Directors, a self-perpetuating body."

5. The Supreme Judicial Court reiterated this misconstruction of Church foundational documents in Weaver v. Wood. In reality, Mrs. Eddy retained complete control over the management of the Church. There was very little the Directors could do without her approval. Moreover, for as long as Mrs. Eddy was alive, the Directors were not, either in theory or practice, a self-perpetuating body; Mrs. Eddy approved all appointments to the Board.

6. Upon Mrs. Eddy's decease, estoppel clauses were intended to dissolve the five-member Board and its activities.

7. The Eustace court recognized the general effect of the estoppel clauses, indicating that the by-law which precluded the adoption of new by-laws or amendment or annulment of existing by-laws, without Mrs. Eddy's consent (Man. 105), operated to estop changes in the Manual following her decease.

8. The Court, however, failed to extend this recognition of the operation of estoppel clauses to Mrs. Eddy's other reservations of power in the Manual.

9. All of the errors stem from the fact that the Eustace court lacked a complete picture of the Founder's intent because it never construed the 1903 and 1904 Deeds of Trust in conjunction with the estoppel clauses; the parties did not consider the possibility that the Founder could have intended to dissolve the worldwide Church organization upon her decease.

10. The Court thus never perceived the four-member Board of Directors as a distinct entity following appointment of the fifth Director. Although the Eustace bill in equity referenced an "amendatory deed. of March 19, 1903, neither the parties nor the Court recognized the significance of this Deed of Trust.

11. The Court clarified the basis of the bill and decision, as an 1898 Publishing Society Deed of Trust and the 1892 Deed to the Directors. The Massachusetts courts never have ruled on the 1903 and 1904 Deeds of Trust.

12. In Dittemore v. Dickey, the Massachusetts Supreme Judicial Court also did not consider the 1903 Deed of Trust, grounding its decision on the 1892 Deed and the Manual. Hence Court findings that there were not two Boards, of four and five members respectively, but only one Board, are incorrect.

13. The Court made other errors; it found that the management of the Church had been in the hands of the Directors since 1901. Actually, Mrs. Eddy retained full control of the Church until her passing in 1910.

14. The Court found no distinction in practice between duties assigned by the 1892 Deed and duties assigned by the Manual. The Court failed to recognize, however, that the powers allotted each board were vastly different.

15. The Court reasoned erroneously that when the number of directors was increased to five, they became trustees as well. Such an outcome would be impossible, given that the trust deed was nonamendable and later deeds continued to name four grantees.

16. The Court found that the five-member Board constituted the appropriate tribunal to dismiss one of its members. This finding was erroneous, because the five-member board was in reality defunct, and could thus have no authority to dismiss one of its members, unless in the attempt to comply with the estoppel clauses, in which case, the clauses also would have precluded further appointments. This decision should also be set aside to the degree that it is erroneous.