United Methodist Rio Texas Conference Board of Trustees v. Alice First Methodist Church F/K/A First Methodist Church of Alice, Texas; Aransas Pass Methodist F/K/A First United Methodist Church of Aransas Pass; Asbury Corpus Methodist Church F/K/A Asbury United Methodist Church; Barksdale Methodist Church F/K/A First United Methodist Church of Barksdale; First Methodist Church of Burnet Texas F/K/A First United Methodist Church of Burnet, Texas; Dewville Methodist Church F/K/A Dewville United Methodist Church; Dripping Springs Methodist Church F/K/A

Fourth Court of Appeals
San Antonio, Texas
MEMORANDUM OPINION

No. 04-24-00424-CV

UNITED METHODIST RIO TEXAS CONFERENCE BOARD OF TRUSTEES,
Appellant

v.

ALICE FIRST METHODIST CHURCH f/k/a First Methodist Church of Alice, Texas;
Aransas Pass Methodist f/k/a First United Methodist Church of Aransas Pass; Asbury Corpus
Methodist Church f/k/a Asbury United Methodist Church; Barksdale Methodist Church f/k/a
First United Methodist Church of Barksdale; First Methodist Church of Burnet Texas f/k/a First
United Methodist Church of Burnet, Texas; Dewville Methodist Church f/k/a Dewville United
Methodist Church; Dripping Springs Methodist Church f/k/a, Dripping Springs First United
Methodist Church, Inc.; First Methodist Church of Eldorado f/k/a First United Methodist Church
of Eldorado; First Methodist Church Ganado Inc.; First Methodist Church Harlingen, Texas, Inc.
f/k/a First United Methodist Church of Harlingen, Texas, Inc.; Ingleside Methodist Church f/k/a
Ingleside United Methodist Church, Ingleside, Texas; Karnes City Methodist Church f/k/a
United Methodist Church Incorporated, Karnes City, Texas; New Life Methodist Church f/k/a
First United Methodist Church of La Grange, Texas; Lampasas Methodist Church f/k/a First
United Methodist Church of Lampasas, Incorporated; Lutie Watkins Memorial Methodist
Church f/k/a Lutie Watkins Memorial United Methodist Church; Louise Methodist Church f/k/a
Louise United Methodist Church; First Methodist Church of Lyford f/k/a First United Methodist
Church of Lyford; Mertzon Methodist Church f/k/a First United Methodist Church of Mertzon,
Texas; First United Methodist Church of Mission, Texas, Inc.; Raymondville Methodist Church
f/k/a First United Methodist Church of Raymondville; Rio First Church f/k/a First United
Methodist Church of Rio Grande City; First Methodist Church, Rocksprings, Texas f/k/a First
United Methodist Church, Rocksprings, Texas; First Methodist San Saba f/k/a First United
Methodist Church of San Saba; Methodist f/k/a First United Methodist Church, Inc. of Taft,
Texas; First United Methodist Church, George West; Iglesia Metodista El Buen Pastor; Leakey
United Methodist Church, Incorporated n/k/a Leaky Methodist Church, Incorporated; and
Wesley Methodist Church of Harlingen, Texas,
Appellees
04-24-00424-CV

From the 285th Judicial District Court, Bexar County, Texas
Trial Court No. 2023CI09762
Honorable Laura Salinas, Judge Presiding

Opinion by: Irene Rios, Justice

Sitting: Irene Rios, Justice
Lori Massey Brissette, Justice
H. Todd McCray, Justice

Delivered and Filed: October 29, 2025

AFFIRMED

Appellant United Methodist Rio Texas Conference (the “Conference”) appeals the trial

court’s order granting the appellees’ (the “local churches”) plea to the jurisdiction. 1 The local

churches sought to disaffiliate with the United Methodist Church (“UMC”) denomination. The

Conference filed suit because the local churches did not comply with the procedures and

requirements outlined by the UMC’s governing document, the Discipline, to disaffiliate from the

UMC. In their plea to the jurisdiction, the local churches argued the dispute involves ecclesiastical

matters and the courts are divested of subject matter jurisdiction to hear the case under the

ecclesiastical abstention doctrine. The trial court agreed with the local churches and granted their

plea to the jurisdiction.

In its first issue on appeal, the Conference argues the trial court has jurisdiction over its

suit because it can apply neutral principles of law to settle the dispute without wading into the

impermissible realm of ecclesiastical issues. In short, the Conference contends the ecclesiastical

abstention doctrine does not divest the court of subject matter jurisdiction over this suit. In its

second issue, the Conference contends that even if the ecclesiastical abstention doctrine divests

the trial court of subject matter jurisdiction, the court nevertheless has jurisdiction to render

1
Although the local churches’ motion was titled a motion to dismiss, the substance of the motion is a plea to the
jurisdiction.

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judgment in the Conference’s favor to enforce its decision on ecclesiastical matters because it is

the higher ecclesiastical authority. We disagree on both fronts and hold the ecclesiastical

abstention doctrine divests the trial court of subject matter jurisdiction to do anything other than

dismiss the case. Accordingly, we affirm the trial court’s order granting the local churches’ plea

to the jurisdiction.

BACKGROUND

The UMC is a global religious denomination that is organized by conferences. Its

organizational structure consists of several levels of conferences, each ascending with a greater

geographic scope. At the lowest level is a local church. The local church is within a district

conference, which is within an annual conference, which is within a jurisdictional/regional

conference, which is within a general conference. “The General Conference is the [UMC’s]

principal governing body.” Okla. Ann. Conf. of the United Methodist Church, Inc. v. Timmons,

538 P.3d 163, 165–66 (Okla. 2023). The appellees are all local churches, and the appellant is the

annual conference covering South Texas. All the appellee local churches are within the appellant

Conference’s geographic region.

According to the Conference, it provides administrative services to the local churches,

“including a pension and health benefits program to the clergy appointed to [the local churches],

which is funded through contributions made by each [local] church” within the Conferences’

region. The local churches also pay an apportionment to the Conference to support its work on

the regional level and the larger UMC. The Conference “also provides access to property, liability

and worker’s compensation insurance for those churches within the Conference that wish to

subscribe in lieu of obtaining their own insurance.” Of course, the local churches pay their

respective share of the premiums. According to the Conference, local churches that do not

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subscribe to the insurance maintained by the Conference must obtain their own insurance coverage

and name the Conference as an additional insured.

According to the Conference, the “2016 Book of Discipline (the ‘Discipline’) is ‘the

instrument for setting forth the laws, plan, polity, and process by which United Methodists govern

themselves.’” 2 “The General Conference enacts the [Discipline], UMC’s governing document.”

Timmons, 538 P.3d at 166. “The [Discipline] includes both matters of doctrine and policy, and

procedures for implementing them.” Id. Although the full text of the Discipline does not appear

in the appellate record, “the general rule according to [the Discipline] is that a [local] church may

disaffiliate, but UMC retains the [local] church[’s] property.” Id.

In 2019, the General Conference voted to allow ordination of pastors who were members

of the LGBTQ community and recognize the ceremonial marriage of LGBTQ members within the

church. According to the local churches’ plea to the jurisdiction, “the [UMC] has experienced a

widely publicized mass exodus of thousands of congregations in the United States who decided to

disaffiliate [from the UMC] due to their religious disagreements with the [UMC’s] internal affairs

surrounding this topic.”

The General Conference also amended the Discipline and added Paragraph 2553. The new

provision created a process for local churches to disaffiliate from UMC based on disagreements

regarding sexuality, while retaining their property. Under Paragraph 2553, a local church can vote

to disaffiliate from the UMC. If a local church votes to disaffiliate from the UMC, the terms and

conditions of the disaffiliation must be established by the board of trustees of the annual

conference; here, the appellant. The terms are to be memorialized in a binding Disaffiliation

2
A complete copy of the Discipline is not part of the appellate record. For this proposition, the Conference cites
portions of the Discipline that are not in the appellate record.

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04-24-00424-CV

Agreement between the Conference and the local church. However, the Disaffiliation Agreement

must include the following terms:

a) Standard Terms promulgated by the General Council on Finance and
Administration to protect the UMC, including a recognition and validity of
Paragraph 2501, notwithstanding the release of property therefrom. 3
b) Apportionments. The local church shall pay any unpaid apportionments for the
twelve-month period prior to disaffiliation, as well as an additional twelve
months of apportionments.
c) Property. A disaffiliating local church shall have the right to retain its real and
personal, tangible and intangible property. All transfers of property shall be
made prior to disaffiliation.
d) Pension Liabilities. The local church shall contribute withdrawal liability in an
amount equal to its pro rata share of any aggregate unfunded pension
obligations to the annual conference. The General Board of Pension and Health
Benefits shall determine the aggregate funding obligations of the annual
conference using market factors similar to a commercial annuity provider, from
which the annual conference will determine the local church’s share.
e) Other Liabilities. The local church shall satisfy all debts, loans, and liabilities,
or assign and transfer them to its new entity, prior to disaffiliation.
f) Payment Terms. Payment shall occur prior to the effective date of departure.
g) Disaffiliating Churches Continuing as Plan Sponsors of the General Board of
Pension and Health Benefits Plans. The UMC believes that a local church
disaffiliating under Paragraph 2553 shall continue to share common religious
bonds and convictions with the UMC based on shared Wesleyan theology and
tradition and Methodist roots, unless the local church expressly resolves to the
contrary. As such, a local church disaffiliating under Paragraph 2553 shall
continue to be eligible to sponsor voluntary employee benefit plans through the
General Board of Pension and Health Benefits under Paragraph 1504.2, subject
to the applicable terms and conditions of the plans.
h) Once the disaffiliating local church has reimbursed the applicable annual
conference for all funds due under the agreement, and provided that there are
no other outstanding liabilities or claims against [t]he UMC as a result of the
disaffiliation, in consideration of the provisions of this paragraph, the applicable
annual conference shall release any claims that it may have under Paragraph

3
Although it appears that Paragraph 2501 is the general provision stating UMC retains property of a disaffiliated
church; this provision of the Discipline is not included in the appellate record. Thus, we are unable to review this
provision of the Discipline.

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04-24-00424-CV

2501 and other paragraphs of The Book of Discipline of The United Methodist
Church commonly referred to as the trust clause, or under the agreement.
There was also a time limit imposed on the local churches option to disaffiliate under

Paragraph 2553. According to Paragraph 2553(2): “The choice by a local church to disaffiliate

with [the UMC] under this paragraph shall be made in sufficient time for the process for exiting

the denomination to be complete prior to December 31, 2023. The provisions of Paragraph 2553

expire on December 31, 2023 and shall not be used after that date.” 4

All the appellee local churches voted to disaffiliate from the UMC. On April 26, 2023, the

local churches advised the Conference through counsel that they did not intend to sign the

Disaffiliation Agreement. Counsel further stated the local churches intend to keep their personal

and real property and had no intention to pay any unfunded pension amount. “However, the

churches [were] open to paying a portion of the apportionments including any owed amounts to

date as part of any mutual agreement.”

On May 16, 2023, the Conference sued the local churches for a declaratory judgment

stating the local churches must comply with the disaffiliation procedures set forth in

Paragraph 2553 of the Discipline to retain possession of their real and personal property and assets.

The Conference also asserted a claim for breach of contract or anticipatory repudiation of the

Discipline, namely the local churches’ failure to abide by Paragraph 2553, and requested the trial

court enjoin the local churches from disaffiliating without abiding by Paragraph 2553.

The local churches filed a plea to the jurisdiction arguing the trial court does not have

subject matter jurisdiction over the suit pursuant to the ecclesiastical abstention doctrine because

resolution of the dispute would require the trial court to interpret ecclesiastical documents and

4
We question whether this appeal would be moot even if we concluded the trial court erred in denying the plea to the
jurisdiction because the disaffiliation process was not completed by December 31, 2023.

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04-24-00424-CV

entangle the courts in religious affairs. The Conference responded arguing the issues involved are

not inherently ecclesiastical in nature and do not require the courts to get entangled in religious

affairs. Rather, the Conference argued the court can resolve this dispute under neutral principles

of law, just like it would if there were non-religious entities involved. Interestingly, the Conference

argued that even if the ecclesiastical abstention doctrine divests the court of jurisdiction, the trial

court should enforce the Conference’s decision to bind the local churches to the disaffiliation

process under Paragraph 2553 because the ecclesiastical abstention doctrine requires the courts to

defer to the higher ecclesiastical body. The trial court granted the local churches’ plea to the

jurisdiction and dismissed the case for lack of subject matter jurisdiction. The Conference appeals.

STANDARD OF REVIEW

A plea to the jurisdiction challenges the trial court’s authority to determine the subject

matter of a specific cause of action. City of San Antonio v. Rogers Shavano Ranch, Ltd.,

383 S.W.3d 234, 241 (Tex. App.—San Antonio 2012, pet. denied). Because subject matter

jurisdiction presents a question of law, we review the trial court’s decision under a de novo

standard of review. Id.

“[T]o prevail, the party asserting the plea to the jurisdiction must show that even if all the

allegations in the plaintiff’s pleadings are taken as true, there is an incurable jurisdictional defect

apparent from the face of the pleadings, rendering it impossible for the plaintiff’s petition to confer

jurisdiction on the trial court.” Tex. Parks & Wildlife Dep’t v. Dearing, 150 S.W.3d 452, 457–58

(Tex. App.—Austin 2004, pet. denied). “When a defendant challenges jurisdiction, a court is not

required to look solely to the pleadings but may consider evidence and must do so when necessary

to resolve the jurisdictional issues raised.” Town of Shady Shores v. Swanson, 590 S.W.3d 544,

550 (Tex. 2019) (internal quotation marks omitted).

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04-24-00424-CV

ECCLESIASTICAL ABSTENTION DOCTRINE

In its first issue, the Conference contends the trial court has jurisdiction over this lawsuit

because the questions of whether the local churches are bound by the Discipline’s disaffiliation

provisions and properly disaffiliated from the UMC can be determined by interpreting the

Discipline using neutral principles of law. We disagree.

“The Free exercise clause of the First Amendment of the United States Constitution

provides that ‘Congress shall make no law respecting an establishment of religion, or prohibiting

the free exercise thereof.’” Masterson v. Diocese of Nw. Tex., 422 S.W.3d 594, 601 (Tex. 2013)

(quoting U.S. CONST. amend. I). “The clause severely circumscribes the role that civil courts may

play in resolving church property disputes by prohibiting civil courts from inquiring into matters

concerning theological controversy, church discipline, ecclesiastical government, or the

conformity of the members of a church to the standard of morals required of them.” Masterson,

422 S.W.3d at 601 (internal quotation marks and citations omitted). “The First Amendment is

applicable to the states through the Fourteenth Amendment.” Id.

Attempts by courts to resolve church property disputes while balancing the competing

interest of property rights and the First Amendment’s Free Exercise provision have resulted in two

general approaches to the issue: “the neutral principles of law” approach and the “deference”

approach. Id. (citing Jones v. Wolf, 443 U.S. 595, 602–10 (1979)). Under either approach, the

court may not resolve a dispute that involves “consideration of doctrinal matters, whether the ritual

or liturgy of worship or the tenets of faith.” Id. (quoting Jones, 443 U.S. at 602).

When confronted with an issue that potentially implicates the ecclesiastical abstention

doctrine, the Texas Supreme Court held Texas courts “should use the neutral principles

methodology to determine property interests when religious organizations are involved.” See

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Masterson, 422 S.W.3d at 607 (“Further, to reduce confusion and increase predictability in this

area of the law where the issues are difficult to begin with, Texas courts must use only the neutral

principles construct.”). “Under the neutral principles methodology, courts decide non-

ecclesiastical issues such as property ownership based on the same neutral principles of law

applicable to other entities, while deferring to religious entities’ decisions on ecclesiastical and

church polity questions.” Id.at 596 (citation omitted). Applying neutral principles of law to

determine disputed ownership of property “will usually include considering evidence such as

deeds to the properties, terms of the local church charter (including articles of incorporation and

[bylaws], if any), and relevant provisions of governing documents of the general church.” Id. at

603, 606 (recognizing “the differences between ecclesiastical and non-ecclesiastical issues will not

always be distinct, and that many disputes [involving religious organizations] will require courts

to analyze church documents and organizational structures to some degree”).

“Courts do not have jurisdiction to decide questions of an ecclesiastical or inherently

religious nature, so as to those questions they must defer to decisions of appropriate ecclesiastical

decision makers.” Id. at 605–06. In this instance, “deferring to decisions of ecclesiastical bodies

in matters reserved to them by the First Amendment may, in some instances, effectively determine

the property rights in question.” Id. at 606; see also Craver v. Faith Lutheran Church, No. 04-22-

00235-CV, 2023 WL 7365302, at *4 (Tex. App.—San Antonio Nov. 8, 2023, no pet.) (“Although

wrongs may exist in the ecclesiastical setting, and although the administration of the church may

be inadequate to provide a remedy, the preservation of the free exercise of religion is deemed so

important a principle it overshadows the inequities that may result from its liberal application.”

(quoting In re Godwin, 293 S.W.3d 742, 748 (Tex. App.—San Antonio 2009, orig. proceeding))).

“But Texas courts are bound to exercise jurisdiction vested in them by the Texas Constitution and

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cannot delegate their judicial prerogative where jurisdiction exists.” Masterson, 422 S.W.3d at

606. “Properly exercising jurisdiction requires courts to apply neutral principles of law to non-

ecclesiastical issues involving religious entities in the same manner as they apply those principles

to other entities and issues.” Id. “A court may exercise jurisdiction over a controversy if it can

apply neutral principles of law that will not require inquiry into religious doctrine, interference

with the free-exercise rights of believers, or meddling in church government.” In re Diocese of

Lubbock, 624 S.W.3d 506, 513 (Tex. 2021) (orig. proceeding). “Thus, courts are to apply neutral

principles of law to issues such as land titles, trusts, and corporate formation, governance, and

dissolution, even when religious entities are involved.” Masterson, 422 S.W.3d at 606.

However, the “First Amendment prohibits civil courts from inquiring into matters

concerning theological controversy, church discipline, ecclesiastical government, or the

conformity of the members of a church to the standard of morals required of them.” Episcopal

Diocese of Fort Worth v. Episcopal Church, 602 S.W.3d 417, 435 (Tex. 2020) (internal quotation

marks omitted). “It is a core tenet of the First Amendment that in resolving civil claims courts

must be careful not to intrude upon internal affairs of church governance and autonomy.” Diocese

of Lubbock, 624 S.W.3d at 513.

Thus, “[i]n determining whether ecclesiastical abstention applies, courts will analyze

whether a particular dispute is ecclesiastical or merely a civil-law controversy in which the church

happens to be involved.” Id. at 514. “In making this determination, we look to the substance and

nature of the plaintiff’s claims.” Id. “Because courts are prohibited from risking judicial

entanglement with ecclesiastical matters, if the substance and nature of the plaintiff’s claims are

inextricably intertwined with matters of doctrine or church governance, then the case must be

dismissed.” Id. (citations omitted)

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This court recognized, “[u]nder a plain reading, the ecclesiastical abstention doctrine would

appear to apply only if claims turn on matters of religious doctrine or practice.” In re Vida, No. 04-

14-00636-CV, 2015 WL 82717, at *2 (Tex. App.—San Antonio Jan. 7, 2015, orig. proceeding).

“The Texas Supreme Court, however, has clarified that government action may burden the free

exercise of religion ‘by encroaching on the church’s ability to manage its internal affairs.’” Id.

(quoting Westbrook v. Penley, 231 S.W.3d 389, 395 (Tex. 2007)); see also Westbrook, 231 S.W.3d

at 397 (“Churches have a fundamental right ‘to decide for themselves, free from state interference,

matters of church government as well as those of faith and doctrine.’” (quoting Kedroff v. St.

Nicholas Cathedral of Russion Orthodox Church in N.A., 344 U.S. 94, 116 (1952))). “If judicial

resolution of the claim will interfere with a church’s management of its internal affairs or encroach

upon the church’s internal governance, the court may not exercise jurisdiction over the claim.”

Vida, 2015 WL 82717, at *2; see also S. Methodist Univ. v. S. Cent. Juris. Conf. of the United

Methodist Church, 716 S.W.3d 475, 482 (Tex. 2025) (internal quotation marks omitted) (“To be

sure, courts must be careful not to intrude upon internal matters of church governance.”).

Latching on to the preclusion of court involvement in church governance, the Fort Worth

Court of Appeals held the trial court lacked jurisdiction to determine whether a church conference

complied with church governing documents when it seized a local church’s funds and locked the

members of the local church out of their place of worship. See In re Tex. Conf. of Seventh-Day

Adventists, 652 S.W.3d 136, 141, 146–49 (Tex. App.—Fort Worth 2022, orig. proceeding)

(“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 Fort

Worth Court of Appeals determined the local church’s claims were “inextricably intertwined with

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matters of doctrine or church governance; because courts are prohibited from risking judicial

entanglement in ecclesiastical matters, the case must be dismissed.” Id. at 149.

Although Masterson indicates a court may look into some church documents to resolve

purely secular questions under neutral principles of law, the local churches argue that the

ecclesiastical document the court is asked to review here—the Discipline—is undoubtedly a

document of church governance, thereby creating a risk of judicial entanglement in ecclesiastical

matters. See id.; see also Diocese of Lubbock, 624 S.W.3d at 517 (citations omitted) (“A civil

court . . . is prohibited from determining whether a church properly applied its own principles and

policies, and from interfering with internal management decisions that are central to its

mission . . . .”). Cf. Shannon v. Mem’l Drive Presbyterian Church U.S., 476 S.W.3d 612, 624–25

(Tex. App.—Houston [14th Dist.] 2015, pet. denied) (determining the court could apply neutral

principles of contract law to determine whether the church disparaged a former employee in

violation of a non-ecclesiastical settlement agreement without intervening in areas traditionally

held to involve religious doctrine, interpreting church governing documents, or deciding matters

of the congregational or hierarchical nature of the church); see also Diocese of Lubbock,

624 S.W.3d at 517–18 (favorably citing Shannon).

Even the dissent in Diocese of Lubbock seems to recognize that a court’s involvement with

church governance crosses the line. Justice Boyd wrote: “Courts cannot resolve ‘church property

disputes on the basis of religious doctrine and practice.’” Diocese of Lubbock, 624 S.W.3d at 523

(Boyd, J., dissenting) (quoting Jones v. Wolf, 443 U.S. at 602). “They cannot hear ‘church disputes

over church polity and church administration,’ or claims involving a religious organization’s

‘internal discipline and government.’” Diocese of Lubbock, 624 S.W.3d at 523 (Boyd, J.,

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dissenting) (quoting Serbian E. Orthodox Diocese for U.S. of Am. & Can. v. Milivojevich, 426

U.S. 696, 710, 724 (1976)).

When analyzing a materially indistinguishable issue from the one presented here, the

Oklahoma Supreme Court concluded the courts did not have jurisdiction to resolve a dispute over

Paragraph 2553 of the Discipline. The Oklahoma Supreme Court held:

Where a dispute involves only narrow property issues, without any reference to
religious doctrine and practice, courts may apply neutral principles of law to review
language of deeds, terms of charters, church provisions concerning property
ownership, and state property and trust statutes. Jones v. Wolf, 443 U.S. 595, 602-
03, 99 S.Ct. 3020, 61 L.Ed.2d 775 (1979). However, a court may not, under the
neutral principles approach, decide for itself what any governing church provisions
mean; the review must be strictly secular, and courts must defer to the church
leadership’s resolution of any religious or doctrinal question. Id. at 604, 99 S.Ct.
3020; Lubbock, 624 S.W.3d at 513. Church autonomy will apply, and a case must
be dismissed, where potentially secular issues are inextricably intertwined with
ecclesiastical decisions. Lubbock, 624 S.W.3d at 514.

Timmons, 538 P.3d at 168. Based on this holding, the Timmons court concluded:

At issue here is whether deciding the merits of the claims of First Church
requires the courts to interpret the Book of Discipline and Paragraph 2553. As the
Book of Discipline is a governing church document, its interpretation is an
ecclesiastical issue. All parties agree that the Book of Discipline is UMC’s
governing document. They also agree that Paragraph 2553 was specially adopted
to address a specific ecclesiastical matter. First Church frames its lawsuit as a
property issue; however, it chose to disaffiliate under the rules of church doctrine
outlined in Paragraph 2553 to claim the property. First Church does not have a
property dispute at this juncture, and it cannot claim to have a dispute at this
juncture without confronting the doctrinal issue explicitly raised by the church-
created procedural language. First Church also claims the UMC has violated its
own procedures outlined in the Book of Discipline. But the only way for the courts
to decide that question is, again, to interpret those internal church procedures.
Under the church autonomy doctrine, courts cannot—and should not—do that.

Id.; see also Ex parte Alabama-West Fla. Conf. of United Methodist Church, Inc., 401 So.3d 1123,

1130 (Ala. 2024) (stating the Conference sought to invoke the ecclesiastical abstention doctrine

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against local churches who sought declarations over who owns the property used by the local

church before it decided to disaffiliate under Paragraph 2553). 5

We find the Timmons court’s reasoning persuasive and note its reliance on our supreme

court’s holding in Diocese of Lubbock. This suit does not involve a dispute over who owns the

real property currently occupied by the local churches. This is a dispute over whether the local

churches are bound to follow the Discipline and the specific provisions providing for disaffiliation

from the UMC. Although our supreme court has held courts may apply neutral principles of law

to issues “such as . . . corporate formation, governance, and dissolution” when a religious entity

has chosen to establish itself under Texas corporations law, see S. Methodist Univ., 716 S.W.3d at

482 (emphasis added), it has rejected parties attempts to have the courts resolve disputes under

church governing documents and regulations because such an inquiry would “intrude upon internal

affairs of church governance and autonomy.” Diocese of Lubbock, 624 S.W.3d at 513. As such,

Masterson allows a court to look at secular documents such as a corporate governance document

to resolve issues that may arise under those documents, but the ecclesiastical abstention doctrine—

and broader church autonomy doctrine—precludes courts from interpreting religious documents

that dictate church governance. See id. (“Government action that interferes with [a religious

5
Alabama-West Fla. Conf. is procedurally different from the case at bar because the local churches sought a judicial
declaration stating the Conference has no right in the local church’s property before it decided to sever affiliation with
the UMC without following the disaffiliation procedures in Paragraph 2553. Ex parte Alabama-West Fla. Conf. of
United Methodist Church, Inc., 401 So.3d 1123, 1128 (Ala. 2024). Nevertheless, the local churches disaffiliated while
the suit was pending and chose not to follow the disaffiliation procedures in Paragraph 2553. Id. Although the
Alabama supreme court held the ecclesiastical abstention doctrine did not apply in that case, it noted the local church’s
“complaint does not seek judicial review of the disaffiliation procedures set forth in the Book of Discipline or
otherwise ask the trial court to judicially declare that [the local church’s] vote to sever its affiliation with the UMC
was consistent with the Book of Discipline’s requirements.” Id. at 1134. “Instead, the complaint asks that the trial
court (1) recognize that [the local church] ‘alone is the absolute, full, exclusive, fee simple owner of all real or personal
property that is owned by [the local church], held for [the local church], or titled in its name,’ (2) to declare that the
UMC and the [Conference] do not have any ‘trust, equitable, or beneficial interest in any of the real or personal
property so owned by [the local church],’ and (3) to prohibit the [Conference] and the UMC from ‘ taking any action
that would directly or indirectly interfere with [the local church’s] use, ownership, or control’ of the local church
property.” Id.

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entities’ autonomy to establish and interpret its own internal rules and regulations] risks judicial

entanglement with a church’s conclusion regarding its own rules, customs, or laws is therefore

prohibited by the First Amendment.”); see also Tex. Conf. of Seventh-Day Adventists, 652 S.W.3d

at 149.

Here, the courts cannot resolve the parties’ obligations under the Discipline without

interpreting that document. Although the Conference points us to isolated provisions of the

Discipline that may contain contractual obligations, it is undisputed that the Discipline includes

both matters of doctrine and governance. See Timmons, 538 P.3d at 166. Because the Discipline

is a doctrinal and church governance document, judicial review and interpretation of the Discipline

risks judicial entanglement with ecclesiastical matters. 6 See Diocese of Lubbock, 624 S.W.3d at

514 (citations omitted) (“Because courts are prohibited from risking judicial entanglement with

ecclesiastical matters, if the substance and nature of the plaintiff’s claims are inextricably

intertwined with matters of doctrine or church governance, then the case must be dismissed.”);

Tex. Conf. of Seventh-Day Adventists, 652 S.W.3d at 149 (holding the inquiry of whether a church

Conference acted in a manner consistent with its church governing documents was an internal

6
After the Texas Supreme Court issued its opinion in Southern Methodist earlier this year, both parties in this case
filed letter briefs arguing the opinion supports their respective positions. See generally S. Methodist Univ. v. S. Cent.
Juris. Conf. of the United Methodist Church, 716 S.W.3d 475, 482–83 (Tex. 2025). In Southern Methodist University,
however, the court was able to analyze a purely secular document—Southern Methodist University’s articles of
incorporation—that happens to involve two religious entities by reviewing the articles against the backdrop of the
Texas Business Organizations Code. Id. In contrast here, we must analyze a religious document that governs churches
affiliated with the UMC and involves obligations from different vertical factions of the church. The articles of
incorporation in Southern Methodist University were like any other non-profit corporate governing documents. The
underlying basis of the articles of incorporation was purely secular to incorporate Southern Methodist University
under the laws of this state, and the obligations that flow from the articles could be determined without consultation
with or entanglement in ecclesiastical issues. Unlike the articles of incorporation in Southern Methodist University,
the Discipline we are asked to review here is built upon a religious foundation and the churches’ governance and
obligations flow from this religious document. To exercise jurisdiction over this dispute would require the courts to
meddle or intrude upon internal matters of church government. See Diocese of Lubbock, 624 S.W.3d at 513; S.
Methodist Univ., 716 S.W.3d at 482.

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matter for the church hierarchy to resolve because the claims were inextricably intertwined with

matters of doctrine or church governance).

This is made even more apparent when we review the Conference’s “Guidelines for

disaffiliation under [Paragraph] 2553” (“the Guidelines”). The Guidelines provide that when a

local church considers disaffiliation under Paragraph 2553, it must enter into a period of

discernment for at least six months during which “the local church/ministry shall:”

• Enter into an intentional time of prayer
• Assess the impact of their decision upon the church, community, and
conference and share a written assessment with its congregation and the District
Superintendent.
• Consider how the church will deal with practical concerns including, but not
limited to 1) the incorporation or reincorporation of the church, 2) how
designated funds and endowed funds will be handled, including notification, or
if required, obtaining the consent of donors, 3) the resolution of any unpaid
loans, 4) the effect of the decision, if any, on any outstanding or pending grants
for ministry, 5) the source and cost of future employee health insurance,
workers compensation insurance, general liability and property insurance and
either tail insurance or suitable indemnification of the [Conference] for any past
liabilities, 6) the process for pastoral succession going forward, and the
congregation’s plans if the current pastor decides not to continue with the
church, and 7) continued participation in an employee or pastoral benefits plan,
if any. For other considerations see the attached agreement.
• Develop and make available to the congregation and the District Superintendent
a plan for either independent operation or affiliation with another
denominational entity and include the theological tenets of the new entity, the
governance structure, the missional goals, and anticipated costs.
• Develop a statement articulating their theological and missional foundations in
seeking disaffiliation for reasons of conscience “related to human sexuality[.]”
• The local church shall hold a minimum of three listening sessions, advertised
to and open to the full professing membership, at least one of which is also
advertised and open to those beyond professing membership, who participate
in the ministries of the church/ministry setting. These sessions shall solicit the
input of these constituents and shall report their findings in the assessment
referenced above. The sessions shall be facilitated by the [D]istrict
[S]uperintendent or their designee. The sessions shall include a discussion of
the theological and missional issues referenced above as well as the practical
considerations set forth above.

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It is clear that various tasks required by the Conference’s disaffiliation process are

ecclesiastical in nature. To name a few, the guidelines require the local churches to enter into a

time of prayer, consider pastoral succession, make available to congregants a plan for

denominational succession that includes the theological tenets of the new denomination, and

develop a statement articulating theological and missional foundations in seeking disaffiliation for

reasons of conscience related to human sexuality. Under the current framework of the

ecclesiastical abstention doctrine, courts have no right to judicially compel a religious entity to

perform any of these actions that are clearly of an ecclesiastical nature. We believe the

Constitution prevents the courts from interfering with the local churches’ decision not to follow

the Conference’s disaffiliation process because it is inextricably intertwined with ecclesiastical

matters.

Further, accepting arguendo the Conference’s contention that the Discipline is a binding

contract between the Conference and the local churches, we note that “[c]ontract terms cannot be

viewed in isolation . . . because doing so distorts meaning.” Pathfinder Oil & Gas, Inc. v. Great

W. Drilling, Ltd., 574 S.W.3d 882, 889 (Tex. 2019). Rather, “we must consider the entire writing

in an effort to harmonize and give effect to all the provisions of the contract so that none will be

rendered meaningless.” Id. (internal quotation marks omitted). This requirement presents two

obstacles to the Conference’s position in this appeal.

First, the Conference has failed to provide an appellate record that contains the entire

Discipline as written during the relevant time-period. See Sareen v. Sareen, 350 S.W.3d 314, 317

(Tex. App.—San Antonio 2011, no pet.) (“It is the appellant’s burden to bring forward an appellate

record showing reversible error by the trial court.”); Enter. Leasing Co. of Hous. v. Barrios,

156 S.W.3d 547, 549 (Tex. 2004) (“[O]n appeal, [appellant in the court of appeals] bears the

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burden to bring forward the record of the summary judgment evidence to provide appellate courts

with a basis to review his claim of harmful error.”). Thus, we are unable to consider Paragraph

2553 in harmony with the entire writing.

Second, even if the entire Discipline were in the appellate record, we would be required to

analyze Paragraph 2553 in harmony with the entire document, including the ecclesiastical

provisions in the Discipline. Because our canons of construction require us to read Paragraph 2553

in the context of the entire Discipline, the contested provision is inextricably intertwined with

ecclesiastical matters. Therefore, it would be impossible to interpret Paragraph 2553 with neutral

principles of law without also intruding into the impermissible realm of ecclesiastical matters. To

do otherwise would risk the courts’ entanglement in internal church affairs and cause the courts to

meddle with church government. See Diocese of Lubbock, 624 S.W.3d at 514. Because courts

cannot review the religious governing documents for compliance without running afoul of

constitutional principles, we conclude the trial court properly granted the local churches’ plea to

the jurisdiction.

Accordingly, the Conference’s first issue is overruled.

DISMISSAL OR ENFORCEMENT

In its second issue, the Conference contends that even if the trial court is divested of subject

matter jurisdiction pursuant to the ecclesiastical abstention doctrine, the court nevertheless has

jurisdiction to enforce the Conferences’ position because it is the higher ecclesiastical authority.

It appears the Conference contends we look to neutral principles of law to resolve issues involving

religious entities when possible but must defer to the higher ecclesiastical authority if the court

determines it does not have jurisdiction to adjudicate the dispute.

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In Southern Methodist University, the supreme court recently rejected this argument from

a regional conference within the UMC. See S. Methodist Univ., 716 S.W.3d at 483. The supreme

court held that “if courts could not decide the case without resolving a religious question or

impeding the church’s authority to manage its own affairs, the result would be dismissal for lack

of jurisdiction, not rendition of judgment granting the Conference (or any other party) affirmative

relief.” Id. (internal quotation marks and citations omitted). Having concluded the courts are

unable to decide this case without impeding the church’s authority to manage its own affairs, we

have no choice but to affirm the trial court’s order granting the local churches’ plea to the

jurisdiction and dismissing the case for lack of jurisdiction.

Accordingly, the Conferences’ second issue is overruled.

CONCLUSION

We affirm the trial court’s order granting the local churches’ plea to the jurisdiction and

dismissing this case for lack of jurisdiction.

Irene Rios, Justice

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