5th Circuit: Defer To State Court Proceedings In Church Property Dispute

African Methodist Episcopal Church v. Lucien, (5th Cir., June 30, 2014), involves appeals in two related cases growing out of a property ownership dispute between the national AME Church and a local congregation, St. James Mission Church. St. James sued in a Louisiana state court seeking to evict several AME national church officers who had taken over the local church building. AME filed a counter suit in federal court seeking a declaration that the break-away members had given up any rights to the property through their dissociation.  AME then removed the eviction action to federal court, claiming diversity of citizenship.  However St. James claimed the removal was improper.  The 5th Circuit agreed, finding the jurisdictional diversity of citizenship lacking. The Court ordered that the eviction proceeding be remanded to state court, and that the federal district court also abstain from deciding the counter-suit until the eviction proceeding is concluded in state court.