In Ex parte Alabama-West Florida Conference of the United Methodist Church, Inc., (AL Sup. Ct., March 6, 2026), the Alabama Supreme Court by a vote of 5-2 granted writs of mandamus in 15 cases involving disputes between break-away Methodist congregations and their parent body. In the cases, the local churches filed quiet title actions in trial courts to clarify that they owned their church buildings after their disaffiliations. The parent body (the Conference and its Board of Trustees) filed counterclaims contending that the church properties belong to, or are held in trust for, the Conference. The trial courts dismissed the counterclaims for lack of jurisdiction, finding that the ecclesiastical abstention doctrine precluded civil courts from adjudicating the disputes. The Conference appealed by filing petitions for writs of mandamus, asking the Alabama Supreme Court to order the trial courts to vacate the orders that dismissed their counterclaims. The local churches contended that writs of mandamus were not the proper vehicle for reviewing the trial courts' decisions. The Supreme Court disagreed.
Justice Sellers, joined by Justice Cook, wrote in part:
If mandamus relief is not available in these cases, the question of subject-matter jurisdiction over the petitioners' counterclaims, which appear for the most part to be allegedly supported by the same sort of secular materials upon which the local churches rely in support of their quiet-title actions, will not be considered until after the parties and the trial courts in each action are, respectively, required to litigate and to preside over the local churches' claims to their final resolution.
At play here is the substantial possibility of significantly wasting the litigants' and the trial courts' time and resources....
It is true that the petitioners also point to trust provisions set out in the United Methodist Church's Book of Discipline, which is the governing document of the United Methodist Church. But that does not transform these actions from standard real-property disputes to ecclesiastical disputes. ...The petitioners' counterclaims, to the extent that they rely on the Book of Discipline, do not appear to require resolution of a dispute over doctrinal or ecclesiastical matters. Instead, the petitioners rely on provisions of the Book of Discipline that, they say, call for the real property at issue to be held in trust and that are referenced or implicated by deeds and other secular legal documents....
Justice McCool and Special Justices Edwards and Minor concurred in the result.
Acting Chief Justice Bryan dissented, saying in part:
Rather than identify an appropriate use of the writ of mandamus established by this Court, the petitioners have inconsistently argued that these cases present an issue of subject-matter jurisdiction, but not really. I do not regard that argument as sufficient to meet their burden under these circumstances....
Justice Mendheim dissented, saying in part:
I understand the main opinion's desire to be helpful in resolving these disputes, but we cannot do so without entangling the courts in matters that are best left to the moral judgments of the parties involved....
... [A] proper understanding "of the ecclesiastical-abstention doctrine should come from a desire to protect religious freedom rather than an unfounded fear that religious ideas might taint our civil jurisprudence."... The neutral-principles-of-law approach ... asks courts to do the impossible: interpret church practices and guidelines through a "secular" lens. ...
If the courts elect to enter this fray between local churches and a church denomination's organizing bodies, they should do so absent any reference to the Book of Discipline and its trust clause because there is no way to read that document or that paragraph "in purely secular terms." Courts should not determine whether ecclesiastical abstention applies in a case based on the false notion that there is a distinct bright line between what is "secular" and what is "religious."
Four Justices recused themselves.
AL.com reported on the decision.
