McCORMICK, Justice.
It is a paradox that disputes among church members, like disputes in families, can become emotional and bitter despite the high motives and essential decency of the people involved. When a schism occurs, the civil courts are sometimes asked to decide which faction is entitled to the property owned by the church. As the present case illustrates, the decision is difficult when church interests in property are not established through traditional legal instruments. The trial court held that title to the local church property was subject to an implied trust in the general church. On defendants’ appeal from the decree for plaintiffs, we affirm. We also affirm on plaintiffs’ cross-appeal from the trial court’s order keeping defendants in possession of the property before the appeal was taken.
The role of civil courts in resolving church property disputes is affected by decisions of the United States Supreme Court construing the impact of the free exercise and establishment clauses of the first amendment of the federal Constitution. Because these decisions set the constitutional limits of state court inquiry, we first briefly summarize their holdings.
The starting point is Watson v. Jones, 80 U.S. (13 Wall.) 679, 20 L.Ed. 666 (1871), a pre-Erie diversity case applying federal common law in resolving a property dispute between a national Presbyterian organization and local churches affiliated with it. The Court characterized three kinds of church property disputes: one in which the title document requires the property to be devoted to use for some specific doctrine; a second in which the property is held by a congregation owing no fealty to a higher church government; and a third in which the local church is subordinate in a hierarchical scheme of ecclesiastical government. Id. at 722-23, 20 L.Ed. at 674. In the third category, which includes Presbyterian churches, the Court posited a principle of compulsory deference to decisions of church government: “It is of the essence of these religious unions, and of their right to establish tribunals for the decision of questions arising among themselves, that those decisions should be binding in all cases of ecclesiastical cognizance, subject only to such appeals as the organism itself provides for.” Id. at 729, 20 L.Ed. at 677.
In Gonzalez v. Roman Catholic Archbishop of Manila, 280 U.S. 1, 50 S.Ct. 5, 74 L.Ed. 131 (1929), the Court imposed a qualification on the deference principle by making it applicable “[i]n the absence of fraud, collusion or arbitrariness.” Id. at 16, 50 S.Ct. at 7-8, 74 L.Ed. at 137. The principle of Watson as qualified in Gonzalez was approved as a Constitutional principle in Kedroff v. St. Nicholas Cathedral of Russian Orthodox Church in North America, 344 U.S. 94, 116, 73 S.Ct. 143, 154-55, 97 L.Ed. 120, 136-37 (1952).
The Supreme Court subsequently held in Presbyterian Church in the United States v. [813]*813Mary Elizabeth Blue Hull Memorial Presbyterian Church, 393 U.S. 440, 89 S.Ct. 601, 21 L.Ed.2d 658 (1969) that civil courts are precluded by the first amendment from deciding doctrinal issues. Id. at 449, 89 S.Ct. at 606, 21 L.Ed.2d at 665. Two local Georgia churches had withdrawn from their affiliation with a national Presbyterian organization. Georgia law recognized an implied trust in favor of the national church conditioned on adherence by the national organization to the same tenets of faith as existed at the time of original affiliation. This principle had been applied in the Georgia courts and resulted in an award of church property to the two local churches. In reversing and remanding, the Supreme Court held that civil courts cannot resolve doctrinal controversies in adjudicating church property disputes. On remand, the Georgia court refused to apply the implied trust theory without the departure-from-doctrine element, holding instead that the local churches were entitled to the property because the deeds to it were in their names. See Presbyterian Church in the United States v. Eastern Heights Presbyterian Church in the United States, 225 Ga. 259, 167 S.E.2d 658 (1969), cert. denied, 396 U.S. 1041, 90 S.Ct. 680, 24 L.Ed.2d 685 (1970).
In Maryland & Virginia Eldership of the Churches of God v. Church of God at Sharpsburg, Inc., 396 U.S. 367, 90 S.Ct. 499, 24 L.Ed.2d 582 (1970), the Court upheld a state court decision awarding property to local churches who withdrew from a general church where the state court based its decision on a state statute, deeds, and local church charters giving property control to the local churches. Governing documents of the general church were found not to give it control of the property. Thus the Supreme Court approved a state court’s adjudication of a property dispute through use of neutral principles of law affecting ownership rather than through use of the compulsory deference approach of Watson. In a special concurrence, Justice Brennan suggested that the Watson and neutral principles approaches were complementary and not merely alternative. Id. at 370 n. 4, 90 S.Ct. at 501, 24 L.Ed.2d at 585.
The Watson approach was approved again in Serbian Eastern Orthodox Diocese for the United States v. Milivojevich, 426 U.S. 696, 96 S.Ct. 2372, 49 L.Ed.2d 151 (1976). The Court also cut back the Gonzalez qualification on the Watson holding by precluding an inquiry into arbitrariness of ecclesiastical decisions. Id. at 712-13, 96 S.Ct. at 2382, 49 L.Ed.2d at 164-65.
Finally, in Jones v. Wolf, 443 U.S. 595, 99 S.Ct. 3020, 61 L.Ed.2d 775 (1979), the Supreme Court held that a state may adopt any of various approaches for settling church property disputes so long as the approach involves no consideration of doctrine. Id. at 602, 99 S.Ct. at 3025, 61 L.Ed.2d at 784. The Court explicitly approved neutral principles as an alternative to the Watson deference approach in resolving hierarchical church property disputes. Id. at 604, 99 S.Ct. at 3026, 61 L.Ed.2d at 785. It distinguished the approaches by noting that compulsory deference, unlike neutral principles, requires inquiry into church polity to determine where church authority lies and whether an ecclesiastical decision of the controversy has been made. In contrast, the neutral principles approach requires examination of sources like those in Maryland & Virginia Eldership to determine where ownership and control of church property is vested. The Court said:
The primary advantages of the neutral-principles approach are that it is completely secular in operation, and yet flexible enough to accommodate all forms of religious organization and polity. The method relies exclusively on objective, well-established concepts of trust and property law familiar to lawyers and judges.
Id. at 603, 99 S.Ct. at 3025, 61 L.Ed.2d at 784-85. The Court concluded that the national church had no interest in the local church property and that title was in the local congregation.
The Jones decision did not resolve the issue of which faction constituted the local congregation, and the case was remanded to permit the Georgia courts to adjudicate [814]*814that issue. The Court suggested two methods that would be consistent with the first amendment. One is a presumptive rule of majority control, “defeasible upon a showing that the identity of the local church is to be determined by some other means ....” Id. at 607, 99 S.Ct. at 3027, 61 L.Ed.2d at 787. The other is a rule of deference to the decision of the church’s hierarchical tribunal. Upon remand, the Georgia court applied a presumptive rule of majority control. See Jones v. Wolf, 244 Ga. 388, 260 S.E.2d 84 (1979).
This court quoted the Watson compulsory deference principle with approval in Bethany Congregational Church v. Morse, 151 Iowa 521, 522-23, 132 N.W. 14, 18 (1911). Other decisions involving hierarchical church disputes are consistent with the Watson approach. See, e.g., Helbig v. Rosenberg, 86 Iowa 159, 53 N.W. 111 (1892); Bird v. St. Mark’s Church of Waterloo, 62 Iowa 567, 17 N.W. 747 (1883); First Constitutional Presbyterian Church v. Congregational Society, 23 Iowa 567 (1867). The departure-from-doctrine concept was employed in resolving disputes between factions of local churches. See, e.g., Ragsdale v. Church of Christ in Eldora, 244 Iowa 474, 55 N.W.2d 539 (1952); Keith v. First Baptist Church of Algona, 243 Iowa 616, 50 N.W .2d 803 (1952). That concept can, of course, no longer be used by the courts.
Plaintiffs in this case include the First United Presbyterian Church, Kamrar, Iowa, four of its members, the Presbytery of North Central Iowa, and the United Presbyterian Church in the United States of America (UPCUSA). Defendants are the Community Church of Kamrar, Hamilton County, Iowa and the trustees of that church. The petition is in equity. Plaintiffs alleged defendants illegally appropriated the real and personal property of plaintiff First United Presbyterian Church of Kamrar which was held in trust for UPCUSA. They asked for an accounting, injunctive relief, and recognition of the trust. Defendants denied the material allegations of the petition, alleged the First United Presbyterian Church of Kamrar became the Community Church of Kamrar through restated articles of incorporation, and asserted property rights and freedom of religion in bar of the action.
Like Jones v. Wolf, the present case involves a hierarchical church and a dispute between factions of the local congregation. The national organization in Jones, however, was the Presbyterian Church of the United States (PCUS) rather than UPCU-SA. The constitution of UPCUSA contains provisions dealing with church government that were not shown in Jones to be in the PCUS constitution. Therefore the neutral principles approach would not necessarily produce the same result in this case.
Our de novo review shows that the Presbytery of Waterloo organized a Presbyterian church in Kamrar in 1875 at the request of a group of German immigrants. The church was called the First German Church of Poland’s Grove in Hamilton County. In 1881, the first minister donated five acres of land to the church. He and others incorporated the church the same year pursuant to what is now the Iowa Nonprofit Corporation Act in Code chapter 504. The church was then named the First Presbyterian Church of Kamrar. It was subsequently reincorporated in 1944 and 1964. In 1964 it was renamed the First United Presbyterian Church of Kamrar. The articles, which were in effect when the present controversy arose, stated the corporation’s purpose was “to operate and maintain a Presbyterian church, affiliated with the General Assembly of the United Presbyterian Church in the United States of America.”
The articles also provided:
All instruments affecting real estate shall be executed in the name of the Corporation by the Trustees. The Trustees shall have authority to acquire, incumber and dispose of the lease property for the Corporation whether said property be real, personal or mixed when authorized to do so by ¾ vote of the members present at a duly called meeting.
The record does not disclose what was meant by reference to “the lease property.” Although the record also does not show how [815]*815the original church property was transferred to the corporation, the parties have assumed throughout this action that the First United Presbyterian Church of Kam-rar held legal title to all the church property when the events resulting in a schism within the local church occurred in 1980. This property consists of approximately seven acres of land and contains a church building, manse, cemetery, small athletic field, and parking lot. Except for the five-acre donation from the first minister, all other property and improvements were acquired through donations to the church corporation from the local church membership. Like the parties, we will assume for purposes of this decision that legal title to the property was in the First United Presbyterian Church of Kamrar in 1980.
It is undisputed that since its initial organization the local church was affiliated with UPCUSA or its predecessors. At all material times, the church governmental structure has been the same. A local church affiliated with UPCUSA is governed by the session, comprised of the pastor and ruling elders elected by the church membership. The next higher governing body is the presbytery, consisting of the ministers and representatives of local church sessions. Each presbytery elects commissioners to the synod, the next higher body, and the general assembly, the highest governing body.
A portion of the constitution of the UP-CUSA is called the Book of Order. It establishes the structure and role of church government. Pursuant to section 34.02 a particular church can be organized only with the approval of the presbytery or its commission. Under section 34.022 the persons “thus received” must subscribe to a covenant including a commitment to “a church relation according to the provisions of the Constitution of the United Presbyterian Church in the United States of America.”
According to section 35.01, the hierarchy of governing bodies is based on the principle that a larger part of the general church, “or a representation of it, should govern a smaller, or determine matters of controversy which arise therein ... and consequently that appeals may be carried from lower to higher judicatories, till they be finally decided by the collected wisdom and united voice of the whole Church.”
Section 41.07 gives the session, the local church governing body, “exclusive authority over the uses to which the church buildings and properties may be put .... ” Section 41.15 provides:
Whenever, after a thorough investigation, and after full opportunity to be heard has been accorded to the session in question, the presbytery of jurisdiction shall determine that the session of a particular church is unable or unwilling to manage wisely the affairs of its church, the presbytery may appoint a commission composed of ministers and ruling elders, with the full power of a session. This commission shall take the place of the existing session, if any, which shall cease to act until'such time as the presbytery shall otherwise direct.
In section 42.08 the presbytery is given jurisdiction to decide appeals “and in cases in which the session cannot exercise its authority, shall have power to assume original jurisdiction ... . ” This includes the power to unite, divide or to dissolve churches. The synod and general assembly are made higher judicatories in sections 43.05 and 44.01.
Section 62.04 requires a local church to be incorporated, if local law permits, “to receive, hold, encumber, manage and transfer property, and to facilitate the management of its civil affairs in such manner as may be directed by the session of the particular church from time to time and according to this Constitution.” Section 62.08 provides that decisions to sell, mortgage or lease real property are subject to control by the session “and to the permission of presbytery as herein provided.” Section 62.12 requires that the permission of the presbytery be in writing. Finally, section 62.11 provides:
Whenever hereafter a particular church is formally dissolved by the presbytery, or has become extinct by reason of the dispersal of its members, the abandonment of its work, or other cause, such [816]*816property as it may have, both real and personal, shall be held, used, and applied for such uses, purposes and trusts as the presbytery may direct, limit, and appoint, or such property may be sold or disposed of as the presbytery may direct, in conformity with the Constitution of the United Presbyterian Church in the United States of America.
Throughout its history, the First United Presbyterian Church of Kamrar participated in and subordinated itself to the general church government of UPCUSA. Permission to build and to borrow was sought and obtained from the presbytery in accordance with the Book of Order.
In October 1980, however, dissension within the local church over general church doctrine caused the governing presbytery, North Central Iowa Presbytery, to establish a commission to investigate the Kamrar situation, to conduct hearings, to act as moderator of congregational meetings and to moderate the session. The commission met with the session and church members without resolving the differences. On October 19, 1980, the membership of the Kam-rar church held a vote on the question:
Shall the members of this church and this Corporation dissolve their affiliation with the United Presbyterian Church in the United States of America, and change the name of the Corporation, and the Church, to Community Church of Kamrar, and shall the attached Restated Articles of Incorporation be adopted?
The theory of the proponents of disaffiliation was that, by voting to disaffiliate and restating the articles of incorporation under chapter 504A of the Iowa Code (1979) to exclude any reference to UPCUSA, the members of the corporation would effectively transfer title of church property to the restated corporation. See Iowa Code .§ 504.18 (1983).
Ballots were distributed only to active members at the meeting. The tally showed 192 votes in favor of the question, 96 votes against it, and four blank ballots. The trustees in control of the meeting declared the question passed and subsequently obtained a restated certificate of incorporation.
When further attempts at reconciliation failed, the presbytery met on November 8 and 22,1980, upon notice to members of the Kamrar church, to determine what action to take. The presbytery adopted its commission's recommendations. It ordered the actions of October 19, 1980, set aside; it dismissed the minister of the local church; it removed the session in accordance with section 41.15 of the Book of Order; and it appointed an administrative commission with full powers of the session including powers of trustees and authority over church property. Defendants did not appeal the presbytery’s decision to a higher church judicatory.
Thus the lines of dispute for the resulting litigation were drawn. After trial, the trial court entered judgment for plaintiffs, ordering an accounting, directing defendants to vacate the property on certain terms, and declaring the property to be subject to a trust in favor of UPCUSA. This appeal and cross-appeal followed.
In deciding the appeal, we will use both the compulsory deference and neutral principles approaches. After deciding the appeal, we will address the cross-appeal.
I. The compulsory deference approach. As made clear in Jones v. Wolf, the Watson compulsory deference approach remains an acceptable method of resolving church property disputes. Under that approach, which has also been approved previously by this court, the decision of the highest authority in a hierarchical church is conclusive on the civil courts in church property disputes. Plainly UPCUSA is a hierarchical church within the meaning of the principle.
Although defendants contend the Kamrar church actually functioned as an ecumenical church, it would require an impermissible inquiry into doctrine for us to determine whether this function was consistent with Presbyterian teachings. In any event, the church was organized by the general church and indisputably subordinat[817]*817ed itself to UPCUSA through expression and action. We find that the First United Presbyterian Church of Kamrar belonged to a hierarchical church. Under the compulsory deference approach, the presbytery’s decision of the property dispute is therefore conclusive.
In analogous situations, other courts using the deference approach have also ruled in favor of UPCUSA. See First Presbyterian Church of Schenectady v. United Presbyterian Church in the United States of America, 430 F.Supp. 450 (N.D.N.Y.1977); Lowe v. First Presbyterian Church of Forest Park, 56 Ill.2d 404, 308 N.E.2d 801, cert. denied, 419 U.S. 895, 95 S.Ct. 174, 42 L.Ed.2d 139 (1974); Presbytery of Indianapolis v. First United Presbyterian Church, 143 Ind.App. 72, 238 N.E.2d 479 (1968); First Presbyterian Church of Schenectady v. United Presbyterian Church in the United States of America, 92 A.D.2d 164, 461 N.Y.S.2d 903 (1983); In re Presbytery of Albany, 35 A.D.2d 252, 315 N.Y.S.2d 428 (1970), aff’d, 28 N.Y.2d 772, 321 N.Y.S.2d 377, 269 N.E.2d 918, appeal dismissed sub nom. Second United Presbyterian Church of Johnstown v. Presbytery of Albany, 404 U.S. 803, 92 S.Ct. 80, 30 L.Ed.2d 35 (1971); Presbytery of Cimarron v. Westminster Presbyterian Church of Enid, 515 P.2d 211 (Okl.1973), cert. denied, 416 U.S. 961, 94 S.Ct. 1980, 40 L.Ed.2d 312 (1974); Presbytery of Seattle v. Bohrbaugh, 79 Wash.2d 367, 485 P.2d 615 (1971), cert. denied, 405 U.S. 996, 92 S.Ct. 1246, 31 L.Ed.2d 465 (1972).
Defendants allege the compulsory deference approach is applicable only to purely ecclesiastical matters. The cases, including Jones v. Wolf, refute this claim. In a hierarchical church, property disputes are resolved by ecclesiastical judicatories.
Defendants also allege the trial court’s decision denies them free exercise of religion under the first amendment and a statutory right to take the church property with them by restating the articles of incorporation under chapter 504A. Nothing in the court’s decision, however, denied individual church members their right to leave
UPCUSA. Their right to leave the church does not include a right to take church property with them. See Bethany Congregational Church v. Morse, 151 Iowa 521, 132 N.W. 14 (1911); Sale v. First Regular Baptist Church of Mason City, 62 Iowa 26, 17 N.W. 143 (1883). The Supreme Court has upheld the compulsory deference approach as recently as its decision in Jones v. Wolf, and no authority supports defendant’s first amendment claim.
Moreover, defendants could not defeat property rights of UPCUSA, if they existed, by merely voting to disaffiliate and restating the local church’s articles of incorporation. If defendants were bound by UPCUSA’s decision as the compulsory deference approach provides, they could not avoid their obligation by pursuing a statutory course inconsistent with that obligation. Nothing in chapter 504A purports to override a general church’s property rights. Having voluntarily submitted to UPCUSA’s system of church government, individual church members were bound by the consequences. The compulsory deference approach makes the decision of the church judicatory conclusive and thus determinative of defendants’ rights in the property.
II. The neutral principles approach. The trial court said the result would be the same under a neutral principles of law approach. Defendants disagree.
The neutral principles approach has been involved in five reported cases involving UPCUSA. They are Presbytery of Riverside v. Community Church of Palm Springs, 89 Cal.App.3d 910, 152 Cal.Rptr. 854, cert. denied, 444 U.S. 974, 100 S.Ct. 469, 62 L.Ed.2d 389 (1979); Babcock Memorial Presbyterian Church v. Presbytery of Baltimore of the United Presbyterian Church in the United States of America, 296 Md. 573, 464 A.2d 1008 (1983), aff’g, 52 Md.App. 428, 449 A.2d 1190 (1982); Calvary Presbyterian Church of Baltimore City v. Presbytery of Baltimore of the United Presbyterian Church in the United States of America, 39 Md.App. ,405, 386 A.2d 357, cert. denied, 283 Md. 731 (1978); First Pres[818]*818byterian Church of Schenectady v. United Presbyterian Church in the United States of America, 92 A.D.2d 164, 461 N.Y.S.2d 903 (1983); and Foss v. Dykstra, 319 N.W.2d 499 (S.D.1982).
In Presbytery of Riverside, the California court affirmed a trial court holding in favor of a local church that unilaterally terminated its affiliation with UPCUSA. The main factual difference between that case and the present one is the extent to which the Palm Springs church functioned as an interdenominational and nondenominational church. The main legal difference is that the Presbytery of Riverside decision was based on a trial court finding of fact that the parties did not intend the national church to have an implied trust in the property. The appellate court found that the evidence gave rise to conflicting inferences on that issue. Applying the substantial evidence test, it therefore affirmed the trial court. In contrast, the trial court in the present case found the evidence showed the local church “had agreed to follow the decisions and procedures of the general church tribunals” in all church matters. Based on the extent of local church subservience, the court found that the local church property was subject to a resulting trust in favor of UPCUSA. In any event, our review in this equity case is de novo.
In Babcock Memorial Presbyterian Church and Calvary Presbyterian Church, the Maryland courts used the neutral principles approach in resolving church'property disputes in favor of UPCUSA. In doing so, they relied heavily on the hierarchial control over local church affairs in the UPCU-SA Book of Order. The Maryland cases are factually analogous to the present one. They illustrate that courts using the neutral principles approach will nevertheless bind the parties to the secular effects of church constitutions and charters.
In First Presbyterian Church of Schenectady, the New York court majority ruled in favor of UPCUSA under the compulsory deference approach. A specially concurring judge and a dissenting judge, however, used the neutral principles approach and reached opposite conclusions on the issue. The views of the specially concurring judge are similar to those expressed in the Maryland decisions.
In the fifth case, Foss v. Dykstra, 319 N.W.2d 499 (S.D.1982), the court did not resolve the merits of the dispute. Instead it merely remanded the case with directions to the trial court to re-examine it under the neutral principles approach.
We conclude that the Presbytery of Riverside case is distinguishable and that the reasoning of the Maryland courts and the specially concurring judge in the First Presbyterian Church of Schenectady case in analogous situations is persuasive. Consequently we agree with the trial court that plaintiffs should prevail on the neutral principles approach in this ease.
The present dispute does not turn on the locus of title. We assume, as do the parties, that title is in the local church. The controversy does turn on whether the UPCUSA constitution, pursuant to and subject to which the local church was organized, establishes an implied trust in UPCU-SA. We believe it does.
When its provisions are construed together, the Book of Order gives UPCUSA exclusive ultimate control of the uses and disposition of local church property. Local church property decisions are subject to general church approval, and the general church may take over local church government, as it did in this case, when it disagrees with local church handling of church affairs. This is a condition of the organization of local churches. It inheres in the governmental relationship established by UPCUSA’s constitution. It is a necessary effect of the comprehensive grant of UP-CUSA judicatory authority over the rights of local church members in property and other matters. See Bethany Congregational Church v. Morse, 151 Iowa 521, 132 N.W. 14 (1911); Sale v. First Regular Baptist Church of Mason City, 62 Iowa 26,17 N.W. 143 (1883). Nothing relating to the locus of title, articles of incorporation or state property law is inconsistent with this system of [819]*819exclusive hierarchical control over the use and disposition of local church property.
The failure of UPCUSA’s General Assembly in 1930 to amend its constitution to provide for an express trust in local church property does not negate the existence, if it otherwise appears, of an implied trust. A 1980 report recites that the 1930 amendment was supported by a majority of churches that voted but failed to carry a majority of those eligible. The report also notes that the general church prevailed in civil litigation on the theory of implied trust before and after the failure of the amendment. Nor does the 1981 action of the General Assembly in adopting such an amendment change our view. The record shows the 1981 amendment was adopted because of uncertainty concerning the effect of Jones v. Wolf on the theory of implied trust. It does not affect our determination based on neutral principles that an implied trust exists as a result of UPCU-SA’s polity giving it determinative authority over the property of its subordinate churches.
We find it unnecessary to decide whether defendants satisfied the statutory requirement of section 504A.39(3) in obtaining the necessary two-thirds votes which the members at their meeting were “entitled to cast” in order to restate the articles of incorporation.
We conclude that the trial court’s decree was correct under both the neutral principles and compulsory deference approaches.
III. The cross-appeal. Plaintiffs’ cross-appeal challenges an order of the trial court staying plaintiffs’ possession of the property until defendants filed notice of appeal and established their right to stay in possession during the appeal by filing a supersedeas bond. We assume, without deciding, that this is not a moot point.
The trial court acted to fill a gap not covered by the rules governing supersedeas. See Iowa R.App.P. 7 and 8. Its authority to do so has been recognized. See Chicago Rock Island & Pacific Railway v. Woods, 196 Iowa 1063, 195 N.W. 957 (1923). We refuse to find that the court’s discretion was abused here.
AFFIRMED ON BOTH APPEALS.
All Justices concur except SCHULTZ, J., and REYNOLDSON, C.J., and HARRIS, J., who dissent.