In In re Texas Conference of Seventh-Day Adventists, (TX App, July 21, 2022), a Texas state appellate court held that the eccleisastical abstention doctrine deprives the trial court of jurisdiction over a dispute between the Fort Worth Northwest Seventh-Day Adventist Church and the Conference, its hierarchical parent body. At issue was control over the Church's funds and property. The court said in part:
The Northwest Church’s suit asks civil courts to resolve its dispute with the Conference based on its rights under the Church Manual. This is precisely the type of civil court inquiry that the First Amendment prohibits....
The Northwest Church’s case is not one in which it has separated from its hierarchical organization and in which it and the hierarchical organization dispute who owns what.... Rather, this is a dispute over who has the authority to make decisions on behalf of the Northwest Church....
Admittedly, under the Church Manual, the local church funds appear to belong to the “local church”.... Nevertheless, the dispute is over whether the Northwest Church is the “local church,” as contemplated by the Church Manual, when the Conference has not recognized the newly elected governing board.
Whether the Conference acted in a manner consistent with the Church Manual is an internal matter for the Northwest Church and the Seventh-Day Adventist hierarchy to resolve.... The Northwest Church’s claims are inextricably intertwined with matters of doctrine or church governance....
