First United Methodist Church of Hobe Sound, Florida, Inc. v. the Board of Trustees of the Florida Annual Conference of the United Methodist Church, Inc.

CourtDistrict Court of Appeal of Florida
DecidedApril 8, 2026
Docket1D2023-1048
StatusPublished

This text of First United Methodist Church of Hobe Sound, Florida, Inc. v. the Board of Trustees of the Florida Annual Conference of the United Methodist Church, Inc. (First United Methodist Church of Hobe Sound, Florida, Inc. v. the Board of Trustees of the Florida Annual Conference of the United Methodist Church, Inc.) is published on Counsel Stack Legal Research, covering District Court of Appeal of Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
First United Methodist Church of Hobe Sound, Florida, Inc. v. the Board of Trustees of the Florida Annual Conference of the United Methodist Church, Inc., (Fla. Ct. App. 2026).

Opinion

FIRST DISTRICT COURT OF APPEAL STATE OF FLORIDA _____________________________

No. 1D2023-1048 _____________________________

FIRST UNITED METHODIST CHURCH OF HOBE SOUND, FLORIDA, INC., et al.,

Appellants,

v.

THE BOARD OF TRUSTEES OF THE FLORIDA ANNUAL CONFERENCE OF THE UNITED METHODIST CHURCH, INC., et al.,

Appellees. _____________________________

On appeal from the Circuit Court for Bradford County. George M. Wright, Judge.

April 8, 2026

NORDBY, J.

This case presents the weighty issue of whether a state court may wade into an intra-church property dispute. Appellants, a group of churches, seek to disaffiliate from the United Methodist Church (UMC) and its clergy. Each of these churches wants to keep its real property when doing so.

The parties litigated the matter internally through UMC’s highest adjudicatory body. That ecclesiastical court concluded that any disaffiliation had to proceed under a specific provision of UMC’s governing document. This ruling meant that Appellants would have to pay a sum of money to UMC in order to retain their property upon disaffiliation.

Appellants then filed this lawsuit to invalidate part of UMC’s governing document. As the trial court described the situation, members of these churches “are faced with either remaining a part of a religious organization they believe has abandoned its central ten[e]ts, or giving up the land where their relatives are buried, the sanctuary where their children were baptized, and the place in their community where the most important moments in their lives are marked.” From UMC’s perspective, Appellants are asking a state court to intrude on a matter already resolved by UMC’s highest ecclesiastical court.

The trial court concluded that, because Florida has adopted a deference approach to property disputes within hierarchical churches, it could not consider Appellants’ property dispute claims. Accordingly, it dismissed the case. For the reasons that follow, we must affirm. That said, we also certify a question of great public importance to the Florida Supreme Court.

I.

In 1968, UMC was founded and established as a hierarchical denomination of Christianity. Structurally, it is a four-tier religious organization. Sitting at the top lies “The General Conference,” followed by regionally divided “Jurisdictional Conferences.” Third are the “Annual Conferences,” and finally, the “Local Churches.”

UMC’s governing document is “The Book of Discipline of the United Methodist Church.” Upon affiliation with the UMC, local churches and members must submit to the Discipline. Submission requires assenting to both theological and practical statements. In 2019, UMC “affirmed its commitment to the greater orthodox doctrine of the universal church,” but Appellants argue that affirmation was in vain. Appellants claim that departures from the Discipline by clergy and other churches caused them to seek disaffiliation. Coinciding with the theological shift, UMC amended

2 the Discipline to change the conditions under which local churches may disaffiliate from the UMC. Previously, potential disaffiliates were governed solely by the “Trust Clause” of the Discipline:

1. All properties of United Methodist local churches and other United Methodist agencies and institutions are held, in trust, for the benefit of the entire denomination, and ownership and usage of church property is subject to the Discipline.

***

The United Methodist Church is organized as a connectional structure, and titles to all real and personal, tangible and intangible property held . . . by a local church or charge, or by an agency or institution of the Church, shall be held in trust for The United Methodist Church and subject to the provisions of its Discipline.

2. The trust is and always has been irrevocable, except as provided in the Discipline. Property can be released from the trust, transferred free of trust or subordinated to the interests of creditors and other third parties only to the extent authority is given by the Discipline.

3. Local churches . . . may acquire, hold, maintain, improve, and sell property for purposes consistent with the mission of the Church, unless restricted or prevented by the Discipline.

The Discipline ¶ 2501 (italics in original). The Discipline also provided specific language that all local churches were required to incorporate into the deeds of their real property. Absence of the provided language, however, did not relieve a local church of its responsibilities towards the mother-church, nor did it absolve the local church from “the responsibility to hold all of its property in trust for” the UMC. The Discipline ¶ 2503.6. Instead, before 2019, for a local church to be relieved of its duties under the Discipline, the governing document provided:

3 With the consent of the presiding bishop and of a majority of the district superintendents and of the district board of church location and building and at the request . . . of a meeting of the membership of the local church, . . . the annual conference may instruct and direct the board of trustees of a local church to deed church property to . . . another evangelical denomination under a[] . . . comity agreement, provided that such agreement shall have been committed to writing and signed and approved by the duly qualified and authorized representatives of both parties concerned.

The Discipline ¶ 2548.2.

But in 2019, the following paragraph was added to the Discipline, modifying how potential disaffiliates were to proceed:

Because of the current deep conflict within The United Methodist Church . . . a local church shall have a limited right, under the provisions of this paragraph, to disaffiliate from the denomination for reasons of conscience regarding a change in the requirements and provisions of the Book of Discipline . . . as resolved and adopted by the 2019 General Conference, or the actions or inactions of its annual conference related to these issues . . . .

The Discipline ¶ 2553.1. Appellants contend that the 2019 addition to the Discipline created onerous and cost prohibitive restraints on disaffiliation. Under this new paragraph, as part of the disaffiliation process, Appellants must pay a sum of money to keep their property. Appellants cannot negotiate nor internally appeal the price for disaffiliation, which is set unilaterally by the Annual Conference.

So, as Appellants describe the situation in their amended complaint, rather than allowing the local churches to amicably disaffiliate under paragraph 2548.2, the Annual Conference is holding Appellants’ property “for ransom” by requiring them to proceed under the newly minted paragraph 2553. The record reflects that, in 2022, the question over which paragraph provided

4 the proper pathway for disaffiliation by local churches was decided by UMC’s highest internal judicial body. In Decision No. 1449, the Judicial Council concluded that paragraph 2548.2 could not be used for disaffiliation; instead, paragraph 2553 provided the sole route for local churches to exit UMC.

Below, Appellants’ amended complaint asserted several counts. Some counts challenged the Trust Clause of the Discipline as invalid for violating chapters 689 (Conveyances of Land and Declarations of Trust) and 736 (Florida’s Trust Code) of the Florida Statutes. Other counts asserted UMC and its Bishop breached a fiduciary duty to the church trust and sought an accounting. UMC responded that the lower court could not adjudicate the claims because of the hierarchical deference approach––an ecclesiastical abstention doctrine under which secular courts defer to a church’s hierarchical authority on matters of internal church governance and intra-church property disputes.

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Bluebook (online)
First United Methodist Church of Hobe Sound, Florida, Inc. v. the Board of Trustees of the Florida Annual Conference of the United Methodist Church, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/first-united-methodist-church-of-hobe-sound-florida-inc-v-the-board-of-fladistctapp-2026.