Robert Masterson, Mark Brown, George Butler, Charles Westbrook, Richey Oliver, Craig Porter, Sharon Weber, June Smith, Rita Baker, Stephanie Peddy, Billie Ruth Hodges, Dallas Christian, and the Episcopal Church of the Good Shepherd v. the Diocese of Northwest Texas, the Rev. Celia Ellery, Don Griffis, and Michael Ryan

Summary

The Texas Supreme Court addresses a dispute over ownership and control of property belonging to an Episcopal parish after a majority of parishioners voted to withdraw from the Episcopal Church and the Diocese of Northwest Texas. The Court holds that Texas courts must apply the neutral-principles methodology to church property disputes rather than choosing between neutral principles and deference. It reverses the court of appeals’ judgment affirming summary judgment for the loyal faction and remands for further proceedings.

Holdings

1. Texas courts must use the neutral-principles methodology, rather than choosing between deference and neutral principles, to determine non-ecclesiastical property interests involving religious organizations.
2. Questions concerning whether a bishop could recognize a parish, determine its membership, establish its vestry, or recognize vestry members are ecclesiastical matters outside civil-court jurisdiction, and courts must defer to the ecclesiastical authority's decisions on those questions.
3. The Bishop's ecclesiastical determination identifying the loyal faction as the continuing Episcopal parish did not, on the record presented, determine ownership of property titled in the nonprofit corporation.
4. The trial court erred in granting summary judgment because the Episcopal Leaders' pleadings and motion asserted entitlement under deference principles, and deference was not the proper methodology for deciding the property dispute.

Questions Presented

1. What methodology must Texas courts use to resolve property disputes involving religious organizations?
2. Whether the Bishop's recognition of the loyal faction as the continuing Episcopal parish established that faction's right to the corporation's property.
3. Whether the trial court properly granted summary judgment based on deference to ecclesiastical decisions when the Episcopal Leaders did not plead or move for summary judgment under neutral principles of law.
4. Whether corporate governance, title, trust, and property questions involving a religious nonprofit corporation must be resolved under neutral principles of law.

Disposition

reversed_and_remanded