In French Broad United Methodist Church v. Holston Annual Conference of the United Methodist Church, (TN App., Oct. 31, 20225), a Tennessee state appellate court affirmed a trial court's dismissal of a local church's suit against its parent body. In this portion of a broader set of claims regarding ownership of a property that had been used as a parsonage, the local church challenged a provision in the Book of Discipline of the United Methodist Church that provided all local church properties were held in trust for the benefit of the denomination. The court said in part:
The trial court determined that Bethel UMC’s claims to quiet title, for a declaration that the trust clause in The Book of Discipline was invalid, and for judicial modification of the trust ... were barred by the ecclesiastical abstention doctrine. Even if the doctrine did not bar these claims, the trial court found that The Book of Discipline would require the dismissal of these claims pursuant to the hybrid neutral principles approach, “under which trust provisions in governing church documents must be enforced.” The trial court noted that the dispute at issue “post-dated the codification of the ‘trust’ provisions of The Book of Discipline.”...
... Tennessee cases dictate that the property dispute between Bethel UMC and Holston is subject to determination in accordance with the hybrid neutral principles approach, which requires a court to defer to and enforce the trust provisions of The Book of Discipline....
Bethel UMC asserts that The Book of Discipline and the trust clause fail because Bethel UMC did not “ever intend to give centuries old properties, worth billions of dollars, away to strangers, when it violates their lives, liberties, freedom, and the pursuit of happiness to worship as they wish without harm to others or in violation of any laws.”
We respectfully disagree with Bethel UMC’s reasoning. The trial court found that, “Bethel admits that it was an affiliate of The United Methodist Church.” The trial court also noted that the dispute at issue “post-dated the codification of the ‘trust’ provisions of The Book of Discipline.” By its affiliation with the national church, Bethel UMC agreed to be bound by the governing documents of the United Methodist Church.... Further, ... Bethel UMC concludes that, instead of applying the ecclesiastical abstention doctrine, “as the long lineage of cases clearly indicates, . . . the legal neutral principles should have been applied to the trial court cause of action, which it was not.” As previously discussed, however, Bethel UMC’s claims were likewise subject to dismissal under that theory, which would require application of the trust provisions.