Court Upholds Parent Church Body's Closing of Church and Takeover of Assets

In Metropolitan District of the Christian and Missionary Alliance v. Community Church of Paramus of the Christian and Missionary Alliance, Inc., (NJ App., March 8, 2013), a New Jersey appeals court rejected a challenge to the decision by the Christian and Missionary Alliance to close the Community Church and acquire title to its assets pursuant to a reversionary clause in the church's constitution. The decision to close the church came after its attendance dwindled and it was discovered that $68,000 in assets had been embezzled. Affirming the trial court's decision upholding the action of the parent body, the appeals court said:

We cannot parse the ecclesiastical constitution and rules of the CMA and the Metropolitan District and then apply neutral principles to determine whether the denomination's designated authority, the district executive committee, properly interpreted and applied such constitution and rules in this case. Matters of church governance, predicated upon its principles and hierarchical structure, should not be the subject of secular judicial resolution. "In disputes involving a church governed by a hierarchical structure, courts should defer to the result reached by the highest church authority to have considered the religious question at issue."