The Texas Supreme Court recently heard oral arguments in the case of Southern Methodist University (SMU) v. South Central Jurisdictional Conference of the United Methodist Church. The dispute arose when SMU amended its Articles of Incorporation in 2019 without obtaining approval from the Conference, which claims that SMU was held in trust for it. The lawsuit includes allegations of breach of contract and fiduciary duties, arguing that SMU’s board lacked authority to amend its articles unilaterally.
This case draws parallels to Hyun Jin Moon, et al. v. The Family Federation for World Peace and Unification International, where similar issues of church governance and amendments to articles were contested but dismissed by the U.S. Court of Appeals due to the ecclesiastical abstention doctrine. This doctrine stems from the First Amendment and restricts courts from intervening in religious disputes.
In the current case, neither SMU nor the Conference initially raised concerns about this doctrine during litigation or before the Texas Supreme Court. However, an amicus brief filed by the Becket Fund for Religious Liberty urged consideration of this issue as a threshold matter. They argue that despite general jurisdictional limitations, the court should rule in favor of the Conference.
First Liberty Institute also submitted an amicus brief supporting dismissal based on ecclesiastical abstention, contending that it precludes such suits entirely. These differing perspectives highlight complexities surrounding denominational schisms and religious institution disputes.
Questions have arisen regarding how this doctrine’s jurisdictional claims might affect cases like these. Some scholars propose adopting a neutral principles approach, allowing courts to decide property disputes without delving into religious doctrines by examining legal documents instead.
Texas has already adopted this approach for church property disputes when doctrinal divisions occur. However, concerns persist that applying neutral principles broadly could intrude on governance matters within religious institutions.
The Texas Supreme Court faces a decision: whether to apply neutral principles or recognize ecclesiastical abstention as barring judicial intervention altogether in this case.
Ultimately, some argue that allowing civil courts to resolve church governance issues risks unintended consequences and that maintaining hesitancy toward involvement aligns with constitutional principles embedded in ecclesiastical abstention.
The outcome will depend on whether justices view neutral principles as appropriate or if they determine that ecclesiastical abstention requires dismissing the case due to lack of subject matter jurisdiction.
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