Central Alabama Conference, African Methodist Episcopal Zion Church in America v. Moore

860 So. 2d 865, 2003 Ala. LEXIS 10, 2003 WL 133247
CourtSupreme Court of Alabama
DecidedJanuary 17, 2003
Docket1011946
StatusPublished
Cited by6 cases

This text of 860 So. 2d 865 (Central Alabama Conference, African Methodist Episcopal Zion Church in America v. Moore) is published on Counsel Stack Legal Research, covering Supreme Court of Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Central Alabama Conference, African Methodist Episcopal Zion Church in America v. Moore, 860 So. 2d 865, 2003 Ala. LEXIS 10, 2003 WL 133247 (Ala. 2003).

Opinion

HOUSTON, Justice.

This appeal involves a property dispute between the Central Alabama Conference, African Methodist Episcopal Zion Church in America (“Central Alabama Conference”) and the congregation of Franklin Church, located in Macon County. The trial court granted Franklin Church’s motion for a summary judgment and determined that Franklin Church owned the [866]*866property on which the church building was located. We issued a writ of certiorari to review the Court of Civil Appeals’ affir-mance, without an opinion, of the trial court’s summary judgment. Central Alabama Conference, African Methodist Episcopal Zion Church in America v. Carl Moore (No. 2000761, May 17, 2002), - So.2d - (Ala.Civ.App.2002) (table). We reverse and remand.

The African Methodist Episcopal Zion Church (“the AME Zion Church”) is a hierarchical church with member churches located throughout the United States. The AME Zion Church was first organized in the United States in 1776. The Central Alabama Conference of the AME Zion Church, which presides over all AME Zion member churches in Alabama, was organized approximately 130 years ago. All AME Zion member churches follow “The Book of Discipline of the AME Zion Church,” which governs member churches with respect to such things as their articles of faith, church government, title to church property, appointment of pastors and presiding elders, the power and authority of bishops, and the organization of annual and general conferences.

Franklin Church, which has maintained a place of worship in Macon County for more than 130 years, has long been affiliated with the AME Zion Church. In the late 1860’s, J.A. Chapman conveyed two acres of land to Franklin Church. The original deed was lost; it was replaced by a deed dated July 17, 1920, which shows the conveyance of the property from Chapman to the “Trustees of Franklin Church.” On April 12, 1947, the trustees of Franklin Church deeded the property to the “Trustees of the Franklin AME Zion Church.” The preamble to the 1947 deed stated that the 1920 deed should have stated that the property was deeded to the “Trustees of the Franklin AME Zion Church.” The final deed, dated November 14, 1999, conveyed the property from the “Trustees of Franklin AME Zion Church” back to the “Trustees of Franklin Church.” Two weeks after the final deed was executed, Franklin Church notified the Central Alabama Conference that it was no longer an AME Zion member church.

Shortly thereafter, the trustees and members of Franklin Church sought in-junctive relief to prevent representatives of the Central Alabama Conference from using or entering the property on which Franklin Church is located. The Central Alabama Conference filed a counterclaim seeking a judgment declaring that the Central Alabama Conference owns the property on which Franklin Church is situated. Franklin Church filed a motion for a summary judgment; the trial court granted the motion, after determining that Franklin Church owns the property at issue. The Central Alabama Conference appealed.

The Central Alabama Conference argues that allowing Franklin Church to unilaterally sever its longstanding relationship with the AME Zion Church contradicts prior decisions of this Court. Specifically, the Central Alabama Conference points to African Methodist Episcopal Zion Church in America, Inc. v. Zion Hill Methodist Church, Inc., 534 So.2d 224 (Ala.1988), in which this Court held that the real property of Zion Hill Methodist Church, the local church, was the property of the AME Zion Church in America, the hierarchical church, under the provisions of the hierarchical church’s governing laws. The Central Alabama Conference contends that the Court of Civil Appeals’ affirmance of the trial court’s summary judgment was incorrect in light of Zion Hill because, it says, there were material issues of fact in dispute as to the effect and interpretation of [867]*867the deeds conveying the property. We agree.

Although this Court cannot resolve disputes concerning the spiritual or ecclesiastical affairs of a church, we can resolve disputes concerning property rights. Central Alabama Conference of the AME Zion Church in America v. Crum, 746 So.2d 1013, 1014-15 (Ala.Civ.App.1999). “However, the First Amendment prohibits a court’s resolving property disputes on the basis of religious practice or doctrine.” Id. at 1015. Alabama courts have adopted the “neutral-prineiples-of-law” approach applied by the United States Supreme Court in Presbyterian Church v. Mary Elizabeth Blue Hull Memorial Presbyterian Church, 393 U.S. 440, 89 S.Ct. 601, 21 L.Ed.2d 658 (1969). Crum, 746 So.2d at 1016. Under the “neutral-principles-of-law” approach, the court considers, in secular terms, “the language of the deeds, the charter of the local church, any applicable state statutes, and any relevant provisions contained in the discipline of the national church” as a means of resolving disputes. Crum, 746 So.2d at 1015.

The Central Alabama Conference argues that Franklin Church is bound by the Book of Discipline of the AME Zion Church. The Central Alabama Conference contends that the Book of Discipline mandates a finding that the property belongs to the AME Zion Church;1 it says that a contrary finding would conflict with this Court’s decision in Zion Hill. In Zion Hill, the local church had withdrawn from its association with the hierarchical church. We found that the local church had agreed to be governed by the hierarchical church’s rules, and we held that the hierarchical church was the equitable owner of the property. We based our decision solely on whether the local church had been associated with the hierarchical church and whether the local church had agreed to be bound by the hierarchical church’s discipline. However, unlike the case before us, [868]*868Zion Hill did not involve a deed, and the Court did not discuss the effect a deed would have had on the dispute.

In Haney’s Chapel United Methodist Church v. United Methodist Church, 716 So.2d 1156 (Ala.1998), the national church sued to quiet title to the church property when the congregation of the local church voted to withdraw from the national church. After conducting an ore tenus hearing, the trial court found in favor of the national church based on the national church’s governing discipline. However, this Court found that the evidence indicated “that the ... grantors intended to convey the property to the trustees of the local church and to exclude the involvement and control of the national church.” Haney’s Chapel, 716 So.2d at 1159-60. Thus, we reversed the trial court’s judgment, holding that the language of the deed, not the governing discipline, controlled. Id. at 1160.

Likewise, Crum, supra, involved another property dispute between a local church and a national church where deeds were involved. After conducting an ore tenus hearing, the trial court found that because the deeds in question did not clearly state that the property belonged to the national church, and because the original grantors did not intend to deed the property to the national church, the local church owned the property. The Court of Civil Appeals affirmed the trial court’s ruling.2 Crum, 746 So.2d at 1017.

In the instant case, three deeds are relevant: the 1920 deed from J.A.

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King v. African Methodist Episcopal Church, Inc.
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Bluebook (online)
860 So. 2d 865, 2003 Ala. LEXIS 10, 2003 WL 133247, Counsel Stack Legal Research, https://law.counselstack.com/opinion/central-alabama-conference-african-methodist-episcopal-zion-church-in-ala-2003.