Central Boston Church v. Southern New England Conference Ass'n of Seventh Day Adventists

30 Mass. L. Rptr. 109
CourtMassachusetts Superior Court
DecidedJuly 5, 2012
DocketNo. SUCV20102761
StatusPublished

This text of 30 Mass. L. Rptr. 109 (Central Boston Church v. Southern New England Conference Ass'n of Seventh Day Adventists) is published on Counsel Stack Legal Research, covering Massachusetts Superior Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Central Boston Church v. Southern New England Conference Ass'n of Seventh Day Adventists, 30 Mass. L. Rptr. 109 (Mass. Ct. App. 2012).

Opinion

Fahey, Elizabeth M., J.

Plaintiff Central Boston Church (“CBC") brought this action against the defendant, Southern New England Conference Association of Seventh Day Adventists (“SNEC”), seeking an order establishing that SNEC holds a certain 2008 Chevrolet passenger van in constructive trust for the benefit of CBC (Count I), seeking a declaratory judgment that SNEC must transfer title to the van (Count II), and seeking monetary damages for wrongful deprivation of. the van’s use (Count III). SNEC filed a Motion for Summary Judgment. CBC then filed a Cross Motion for Summary Judgment. For the reasons stated below, the defendant’s Motion for Summary Judgment is DENIED. The plaintiffs Cross Motion for Summary Judgment is also DENIED.

BACKGROUND

This case involves a dispute between two religious organizations over the ownership of a 2008 Chevrolet van. The plaintiff, CBC, is a nonprofit organization organized under the laws of the Commonwealth of Massachusetts with a principal place of worship at 131 Cambridge Street, Boston. The defendant, SNEC, is a nonprofit organization, also organized under the laws of the Commonwealth of Massachusetts, with a principal office at 34 Sawyer Street, Lancaster, Massachusetts. SNEC is a subdivision of the larger, global General Conference of Seventh Day Adventists, and it oversees a sisterhood of member churches located throughout Massachusetts, Connecticut, and Rhode Island.

CBC formed in 2002 and began operating as an independent church group. For a time, it held services at the Old West United Methodist Church in Boston. In the following years, however, CBC’s membership grew and it sought to become affiliated with a larger religious organization. In 2006, CBC officers met with representatives from SNEC and another conference of Seventh Day Adventists in order to discuss becoming a part of one of their regional organizations. CBC ultimately chose to affiliate with SNEC. By petition dated June 14, 2006, CBC, as an independent congregation, submitted to become a “church company” within the umbrella of SNEC.

“Church companies,” discussed in greater detail below, are small congregations of worshipers who have expressed a desire to become members of a conference and who are midway through the process of becoming an organized church. “Local organized churches” are distinct and separate entities, and the process by which a church company may apply to become an official organized church is described in detail in the General Conference’s Church Manual. CBC had not yet completed this process by the time this dispute arose.

According to the General Conference’s Church Manual:

Where a number of isolated believers reside in proximity to one another, a company of believers may be organized for fellowship and worship with the objective of growing into an organized church. Such a group of believers may be organized as a company by approval of the conference/mission/field committee and may subsequently be dissolved by action of the conference/mission/field committee . . . Such a company of believers should grow and eventually develop to the point that would call for a regular church organization. The company leadership should therefore promote and foster all the church campaigns and activities that are usually carried forward by regular churches, thus preparing the members for the wider responsibilities that are associated with full church organization.

Gen. Conf. of Seventh-Day Adventists, Church Manual 40-41 (17th ed. 2005). As a church company, CBC was required to open a checking account, which it did under the name “Central Boston Seventh Day Adventist Church,” and was required to submit all tithes and offerings, except for those funds collected for local purposes, to SNEC through the account.

In 2007, one of the plaintiffs parishioners, Milagros Garcia, made a donation of $20,000 to CBC by check in honor of her son who had died in combat in Iraq. [110]*110Garcia had attended services at CBC fairly regularly before it became affiliated with SNEC. However, she only became a registered member after CBC became a church company. The stated purpose of her donation was to provide funds for CBC to purchase a new passenger van for its parishioners. The board of CBC then voted to purchase a van for CBC’s use with the money from the donation and from additional funds it collected.

The van that is the subject of this action was purchased on January 31, 2008 by representatives of CBC. CBC officers selected a 2008 Chevrolet passenger van with a total purchase price of $29,694.00. The purchase money for the van was paid for entirely by CBC from Garcia’s donation and from its own funds. SNEC did not contribute any amount to the purchase price. Title to the van was placed in SNEC’s name, however.

CBC maintains that this was done for insurance purposes only. It alleges that SNEC’s Secretary and Property Manager, Jeffery Linthwaite, (“Linthwaite”) negligently misrepresented to CBC officers that they would be able to obtain a lower insurance premium if the van was titled in SNEC’s name. Linthwaite also allegedly told CBC that, pursuant to SNEC policy, even though title would be in SNEC’s name, the van would still be CBC’s property.

CBC subsequently learned that they would have to pay thousands of dollars more in premiums each year through SNEC than if they had sought insurance on their own. SNEC allegedly initially quoted CBC $1,500.00 to $1,700.00 per year. CBC was subsequently billed for nearly $11,000.00, more thanathird of the total purchase price of the van. Other disputes between CBC and SNEC arose, principally concerning the pastor that SNEC had assigned to CBC. Due to these difficulties, CBC voted to disaffiliate with SNEC. SNEC then informed CBC that SNEC’s Executive Board would also have to vote on CBC’s disaffiliation. SNEC’s Executive Board held a meeting and voted to allow CBC to disaffiliate. It did not, however, discuss whether CBC should be considered “dissolved,” which has a different technical meaning than disaffiliating. CBC continues to exist as a nonprofit organization and has not ceased holding services. More than 90% of its members have stayed within its organization. A few former members, however, have left CBC to join churches under SNEC’s regional administration.

Shortly after disaffiliation with SNEC, CBC requested that title to the subject van be changed to name CBC as the titleholder. As a result of the request, the SNEC Executive Board held a meeting to discuss ownership of the vehicle. The Board subsequently denied the plaintiffs request for title to the van. The van currently remains in the physical possession of CBC. However, because CBC does not hold title to the van, it is uninsurable and unusable. After failing to resolve the dispute through negotiations, CBC instituted the present action. Ms. Garcia has also sent SNEC a letter expressing her concern and stating that she would not have donated the money for the van if she knew it would become SNEC’s property.

SNEC argues that the court lacks subject matter jurisdiction to hear the plaintiffs claims because the dispute allegedly involves matters of church doctrine. In the alternative, it argues that upon becoming a “church company” within its organization, CBC agreed to be bound by the General Conference’s official Church Manual and that under the relevant provisions in the Church Manual, which are discussed below, title to the van was properly placed in the hands of the conference.

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Bluebook (online)
30 Mass. L. Rptr. 109, Counsel Stack Legal Research, https://law.counselstack.com/opinion/central-boston-church-v-southern-new-england-conference-assn-of-seventh-masssuperct-2012.