Defendant local church organizations, who withdrew their affiliation from plaintiffs

 

Procedural Posture

Defendant local church organizations, who withdrew their affiliation from plaintiffs, regional and national church bodies, sought review of a decision from the Superior Court of Los Angeles County (California). The superior court determined that under a theory of hierarchy and implied trust, plaintiffs were the rightful owners of church property held in defendants' name.

 

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Defendant local church organizations withdrew their affiliation from plaintiffs, regional and national church bodies. Plaintiffs were awarded judgment by the superior court, which granted them title to property held in the names of the local churches. Defendants appealed and the court reversed in part and affirmed in part. The court held that the superior court's theories of hierarchy and implied trust were rejected as impossible to administer. The court held that ownership of church property was determined by neutral law which examined whether an express trust existed from the deeds to the property, the articles of incorporation of the local church, the constitution, canons, and rules of the general church, and relevant state statutes, if any, governing possession and disposition of such property. The court reversed for three defendants because there was no express trust and the court held that defendants owned the property. The court affirmed against the remaining defendant, as their articles of incorporation provided for a return of property to plaintiff national church body upon termination of its charter.

 

Outcome

The court first rejected both hierarchy and implied trust theories. The court reversed for three defendant local church organizations and held that under neutral principles of law, there was no express trust and defendants owned the property. The court affirmed against the remaining defendant, as its articles of incorporation provided for a return of property to plaintiff national church body upon termination of its charter.