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Calvary Presbyterian Church v. Presbytery of Baltimore of United Presbyterian Church

Citations: 386 A.2d 357; 39 Md. App. 405; 1978 Md. App. LEXIS 212Docket: 1114, September Term, 1977

Court: Court of Special Appeals of Maryland; May 12, 1978; Maryland; State Appellate Court

Narrative Opinion Summary

The case involves a dispute between a local church, referred to as Calvary, and the denominational body, United, over the ownership of church property following Calvary's decision to disassociate from United. The conflict arose after Calvary voted to align with another Presbyterian branch while maintaining Presbyterian doctrine. The court focused on whether Calvary retained possession and control of its property absent specific charter provisions and despite a legislative amendment that altered its charter without consent. The legal questions centered on church property rights and the extent to which civil courts can resolve such disputes without infringing on First Amendment protections. The court upheld the decision of Judge Sullivan, affirming that property ownership must be resolved using neutral legal principles rather than religious law, and concluded that Calvary's property was held for the benefit of United. This decision was supported by constitutional provisions and legislative amendments favoring United's control over local church properties within its hierarchical structure. The ruling emphasized the application of neutral principles to avoid ecclesiastical entanglement and maintained the property title with United, assigning costs to Calvary.

Legal Issues Addressed

Church Property Ownership and Withdrawal

Application: The court must determine property ownership based on governing documents and actions without making ecclesiastical judgments.

Reasoning: The standard for courts is to determine if property control can be resolved based on the governing documents and actions of the involved parties without making ecclesiastical judgments.

Control of Church Property by Hierarchical Denominations

Application: The United Presbyterian Church utilized constitutional provisions and legislative acts to maintain control over local church property, implying Calvary holds its property title for the benefit of United.

Reasoning: The United Presbyterian Church has utilized two of these methods to maintain control over local church property, indicating that Calvary holds its property title for the benefit of United.

Judicial Deference to Church Judicatories

Application: Decisions of the highest church judicatories regarding discipline, faith, or ecclesiastical matters are final and binding on legal tribunals.

Reasoning: Decisions made by the highest church judicatories regarding discipline, faith, or ecclesiastical matters are considered final and binding on legal tribunals in relevant cases, as established in Watson v. Jones.

Neutral Principles of Law in Church Disputes

Application: Courts can resolve property disputes involving churches as long as they do not engage in ecclesiastical matters.

Reasoning: The excerpt clarifies that courts can resolve property disputes involving churches as long as they do not engage in ecclesiastical matters.