Latin American Council of Christian Churches v. Leal

Citations: 57 N.M. 502; 260 P.2d 697Docket: No. 5561

Court: New Mexico Supreme Court; August 13, 1953; New Mexico; State Supreme Court

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This case involves a dispute between a local church congregation and its parent church regarding the possession of local church property. The general church (plaintiff) initiated an ejectment action to assert its right to the property, while a faction of the local congregation argued they could sever ties with the general church and claim ownership. The defendants appealed a judgment favoring the plaintiff, arguing that the lower court erred by not dismissing the case due to the absence of necessary parties who were not served and did not appear at trial. They also contested the court's ruling that recognized the plaintiff as the legal or beneficial owner of the property.

Material facts include the formation of a local congregation in Las Cruces, New Mexico, in 1935, which sought affiliation with the plaintiff, a Texas-based religious corporation established in 1923 and authorized to operate in New Mexico since 1943. The plaintiff’s governance structure is ecclesiastical, with property held by the parent church and local ministers appointed by it. Following the affiliation, misunderstandings arose regarding property acquisition, leading to the president of the plaintiff removing the local pastor to allow the congregation to proceed with property matters. Ultimately, the congregation voted to remain affiliated with the plaintiff and agreed to hold property in the plaintiff’s name, resulting in the conveyance of five parcels of land to various designated trustees associated with the local church.

In 1944, Ramon Lucero, a trustee and church official, presented deeds to the plaintiff at a convention, but objections arose regarding their execution. He returned to Las Cruces and attempted to prepare correction deeds, which were never fully executed due to the inability of all trustees to sign. At trial, both the original and correction deeds were in Lucero's possession. Relations between the local church and the plaintiff soured in 1948 after a disagreement led to the resignation of Alejandro Leal, the District Supervisor, resulting in a schism where some local members rejected the plaintiff's authority over the church property.

The lower court found that the plaintiff was the grantee in the deeds, except where conveyances were made to trustees, in which case the plaintiff was the beneficiary. It determined that the defendants, who ousted the plaintiff from the property around April 20, 1948, had retained possession to the exclusion of the plaintiff. The court concluded that the plaintiff was the legal and beneficial owner of three parcels and that the defendants were estopped from claiming any ownership, having been aware of the plaintiff's title.

The defendants argued that the court erred by not dismissing the complaint due to the absence of certain necessary parties—trustees who were not served. They claimed the plaintiff could not proceed against some trustees without including all. However, the action was for wrongful ouster in the defendants' individual capacities, not for trust-related issues. The court referenced that only those in actual possession are necessary parties in ejectment actions, which did not apply to the omitted trustees, who had no claimed adverse interest.

Any individual with an interest adverse to the plaintiff or claiming title or possession may be made a defendant in civil actions, although such individuals may not always be necessary parties; only those in actual possession are mandated to be joined. Failing to include parties not in possession leaves the issues open to later disputes regarding title or rights. Relevant legal provisions include New York's Code of Civil Procedure sections 1502 and 1503, which specify that the occupant must be named as a defendant, while others with claims can also be joined. The court found no merit in the defendants' claim that omitted trustees were necessary parties. The plaintiff is asserted to be the legal and beneficial owner of certain real estate parcels, despite the defendants' arguments refuting this based on the local group's claim to ownership and their possession of the properties. The principles regarding possession rights within church congregations were established in Watson v. Jones, distinguishing between property held under specific religious intentions, independent congregations, and those affiliated with larger church organizations.

The Court emphasized the duty of the judiciary to prevent the diversion of property held in trust for religious use, regardless of the church governance structure (independent or ecclesiastical). In cases where property control is vested in a majority of the congregation or its local governing body, the Court recognizes challenges arising from internal divisions, particularly in cases of schism. Such disputes often involve determining the rightful use of property purchased for a religious congregation, where the congregation's identity or succession must be established. The law supports the right to freely practice religion, form associations, and create governing bodies that adjudicate faith-related issues, binding members to these governing structures through implied consent.

In the case at hand, the appellants have severed ties with their original church organization, rejecting its authority and forming a new entity, potentially hostile to the original. Consequently, they lack rights to the property in question, as established legal precedents, particularly Watson v. Jones, indicate that property acquired by a local church affiliated with a parent church remains under the governance of that parent church. Withdrawal from such affiliation must be consensual and cooperative with the parent church's governance; otherwise, the property cannot be rightfully claimed by the withdrawing faction.

The rule concerning property conveyance under a specific trust for religious purposes is influenced by precedents such as Marr v. Galbraith and Barkley v. Hayes. In these cases, it is established that property deeds to trustees of a religious organization are generally interpreted to create a specific trust for the benefit of the congregation, supporting the church's doctrines. However, this specific trust does not preclude changes by legitimate successors. The court emphasized that as long as a legitimate religious congregation can be identified, it is entitled to use the property, which belongs to the broader church organization rather than to individual congregations or members. The local congregation is subordinate to the larger church structure, governed by higher ecclesiastical authorities that maintain ultimate control over property ownership. This governance is defined by a republican and representative framework, placing decision-making authority in the general assembly and presbyteries. The Barkley case, which involved a merger of Presbyterian Church branches, highlights similar issues of property control and governance that are relevant to the present matter.

The principles from Watson v. Jones and Barkley v. Hayes have been consistently upheld by the courts. Recent relevant cases include Britton v. Jackson, Board of Trustees v. Mount Carmel C.C. Ass’n, Clay v. Crawford, Kelly v. McIntire, Presbytery of Bismarck v. Allen, Church of God v. Church of God, Turbeville v. Morris, and Presbytery of Huron v. Gordon. In the current case, there are no grounds to deviate from the established rule from Watson v. Jones, affirming the lower court's ruling on legal and beneficial ownership and right to possession of the property. The defendants claim that the deeds were not effectively delivered to the plaintiff since they were in the possession of defendant Lucero, who coordinated the property purchase and is named trustee in two deeds. However, this argument is rejected. The court found that the plaintiff is the grantee or beneficiary in all deeds, a finding unchallenged by the defendants. The deeds were recorded, presumably by Lucero, who was a member of the local church linked to the plaintiff and held the deeds with the understanding that all property must be vested in the plaintiff, a condition accepted by the local congregation. The lower court's judgment is affirmed.