First United Methodist Church of Hobe Sound, Florida, Inc. v. The Board of Trustees of the Florida Annual Conference of the United Methodist Church, Inc.

Summary

The First District Court of Appeal affirmed dismissal of claims brought by local United Methodist churches seeking to invalidate the denomination’s trust clause and retain property after disaffiliation. The court held that Florida’s hierarchical-deference approach barred judicial resolution of the intra-church property dispute and rejected the churches’ constitutional challenge to that approach. The court certified a question of great public importance to the Florida Supreme Court concerning whether such disputes may instead be resolved under neutral principles of law.

Holdings

1. Florida courts remain governed by the hierarchical-deference approach when resolving property disputes arising within hierarchical churches. Because the United Methodist Church is hierarchical and the appellants are local churches affiliated with that hierarchy, the courts could not adjudicate the appellants' claims challenging the Church's internal resolution of the disaffiliation and property dispute.
2. The hierarchical-deference approach applies when the court determines first that the religious institution is hierarchical and second that the local church is affiliated with and subordinate to that hierarchy.
3. The appellants failed to establish that Florida's hierarchical-deference doctrine violates the Establishment Clause by impermissibly favoring hierarchical churches over congregational churches.
4. The court declined to consider the appellants' equal-protection and due-process challenges because they were not raised below.

Questions Presented

1. Whether Florida courts must apply the hierarchical-deference approach when adjudicating state-law claims arising from an intra-church property dispute involving a hierarchical church.
2. Whether the appellants' challenge to the United Methodist Church's Trust Clause could be resolved under neutral principles of law rather than through deference to the church's highest ecclesiastical tribunal.
3. Whether application of the hierarchical-deference doctrine violated the First Amendment's Establishment Clause by favoring hierarchical churches over congregational churches.
4. Whether the appellants' unpreserved equal-protection and due-process challenges could be considered for the first time on appeal.

Disposition

affirmed