In Methodist Church of Cape St. Claire v. Baltimore Washington Conference of the United Methodist Church, (MD App., Oct. 5, 2026), a Maryland state appellate court held that the ecclesiastical abstention doctrine prevents civil courts from adjudicating the claim of 37 local churches that their parent body wrongly imposed a charge of 50% of the value of a church's property on local congregations that wished to disaffiliate and retain their property. The General Conference had created a procedure for local congregations that objected to the church's policy on human sexuality to disaffiliate, with regional Conferences being able to add conditions. The 50% payment requirement was added by the BW Conference. The appeals court said in part:
The Local Churches argue first that the circuit court ignored viable exceptions to the ecclesiastical abstention doctrine and dismissed their constructive fraud, breach of fiduciary duty, and breach of contract claims incorrectly....
Resolving the claims alleged in this case would require a trial court to examine the UMC’s religious doctrine and the Conference’s management of church resources in a manner prohibited by the First Amendment. We look first at the Local Churches’ allegation that the Conference engaged in constructive fraud and breached its fiduciary duty by failing to act in their best interest and in accordance with the UMC’s doctrine, custom, and practices....
We reach the same conclusions with respect to the Local Churches’ claims that the Conference committed constructive fraud and breached its fiduciary duty by mismanaging church funds or by making misrepresentations about its use and management of those funds....
In this case, the circuit court properly declined to enforce the Book of Discipline against the Conference as the Local Churches requested because it couldn’t interpret the Book of Discipline “under ‘neutral principles of [contract] law,’ without court involvement ‘in any theological or doctrinal matter.’” ...
Whether the General Conference’s amendment of the Book of Discipline to include Paragraph 2553 contradicted longstanding church practices and existing provisions of the Book of Discipline allegedly allowing local churches to disaffiliate without forfeiting their real property is a question for the UMC’s Judicial Council to answer. And according to the Conference, the Judicial Council has, in fact, answered it.
Finally, the court held that the trial judge who is a Methodist did not need to recuse himself, saying in part:
Ultimately, the judge’s sole connection to the controversy in this case is that he is a parishioner of a church that falls under the regional purview of a party to the case, the BW Conference. His religious affiliation and status as a parishioner, without more, do not qualify as grounds to question his impartiality and do not, on their own, suggest that the judge had an interest in the outcome of the case one way or the other....
