McKnight v. Wakefield Missionary Baptist Church, Inc.

2021 NCBC 35
North Carolina Business Court·Decided June 14, 2021·No. 20-CVS-8299·Published

Opinion

McKnight v. Wakefield Missionary Baptist Church, Inc., 2021 NCBC 35.

STATE OF NORTH CAROLINA IN THE GENERAL COURT OF JUSTICE SUPERIOR COURT DIVISION

WAKE COUNTY 20 CVS 8299

CHARLOTTE MCKNIGHT and AUDREY FOSTER, in their official capacities as Trustees for and on behalf of WAKEFIELD MISSIONARY BAPTIST CHURCH, AN UNINCORPORATED ASSOCIATION,

Plaintiffs,

ORDER AND OPINION ON

v. DEFENDANTS’ MOTION TO DISMISS

WAKEFIELD MISSIONARY BAPTIST CHURCH, INC.; BARBARA WILLIAMS; APRIL HIGH; ALTON HIGH; EKERE ETIM; ROSALIND ETIM; HOUSTON HINSON; NATALIE HARRIS; and DARRYL HIGH,

Defendants.

WAKEFIELD MISSIONARY BAPTIST CHURCH, INC.,

Counterclaim

Plaintiff,

v.

CHARLOTTE MCKNIGHT; AUDREY FOSTER; LEROY JEFFREYS; and JULIUS MONTAGUE, in their official capacities as Trustees and/or Officers for and on behalf of WAKEFIELD MISSIONARY BAPTIST CHURCH, AN UNINCORPORATED ASSOCIATION,

Counterclaim

Defendants.

1. For over 150 years, Wakefield Missionary Baptist Church existed as an unincorporated religious association. Recently, the congregation has splintered due to disputes over church finances and other matters. The schism has led to at least three lawsuits, this being the latest.

2. The plaintiffs, Charlotte McKnight and Audrey Foster, are church trustees. They allege that another group of trustees, improperly and without authorization, converted the church into an incorporated entity and transferred its real property to that new entity. McKnight and Foster have sued on behalf of the unincorporated association to void the reorganization and to unwind the transfers of church property.

3. The defendants have moved to dismiss all claims. For the following reasons, the Court GRANTS in part and DENIES in part the motion.

Michael A. Jones & Associates, P.L.L.C., by Michael A. Jones, for Plaintiffs/Counterclaim Defendants Charlotte McKnight and Audrey Foster and for Counterclaim Defendants Leroy Jeffreys and Julius Montague.

Kitchen Law, PLLC, by S. C. Kitchen, for Defendant/Counterclaim Plaintiff Wakefield Missionary Baptist Church, Inc. and for Defendants Barbara Williams, April High, Alton High, Ekere Etim, Rosalind Etim, Houston Hinson, Natalie Harris, and Darryl High.

Conrad, Judge.

I.

BACKGROUND

4. The following background assumes that the allegations of the verified amended complaint are true. (See First Am. Verified Compl., ECF No. 33 [“Compl.”]; Verification of Am. Compl., ECF No. 38.)

5. Wakefield Missionary Baptist Church (“WMBC”) is an unincorporated religious association with a constitution and bylaws establishing the structure and leadership of the church. (See Compl. ¶¶ 5, 17; Compl. Ex. 1, Wakefield Missionary

Baptist Church Constitution & Bylaws, ECF No. 33.1 [“WMBC Const.”].) Under the constitution and bylaws, the church is governed by “its members,” it “is subject to the control of no other ecclesiastical organization,” and “none of its Ministries or Committees can usurp its executive governance or policy-making powers.” (WMBC Const. Art. III, § 1; see also Compl. ¶ 17.)

6. In 2019, internal disputes about church finances split the congregation. (See Compl. ¶ 16.) Caught in the middle, United Community Bank warned that it might have to file an interpleader action to determine who had authority over the church’s bank accounts. (See Compl. ¶¶ 19, 20.) To avoid that, the church called a business meeting to elect new signatories to the accounts. McKnight and Foster were among those elected. (See Compl. ¶¶ 19–23.) As alleged, though, a group of the church’s trustees (the “Trustee Defendants”) refused to recognize the vote. (See Compl. ¶ 24.) The bank filed an interpleader action, (see Compl. ¶ 38), which remains pending in Wake County Superior Court (No. 19 CVS 9973) (the “Interpleader Action”).

7. In the weeks after the business meeting, the feud escalated rapidly. The Trustee Defendants terminated the senior pastor’s employment contract, locked the doors to the church building, and purported to reorganize the church as a nonprofit corporation called Wakefield Missionary Baptist Church, Inc. (“WMBC Inc.”). (See Compl. ¶¶ 18–25, Ex. 3, ECF No. 33.3.) Later, the Trustee Defendants transferred the church’s real property to WMBC Inc. (See Compl. ¶ 29, Exs. 4, 5, ECF Nos. 33.4, 33.5.) As alleged, they had no authority under the church constitution and bylaws to do any of these things. (See Compl. ¶¶ 24, 25, 29, 35, 36, 38–40; see also WMBC Const. Art. III, § 1; Art. VIII, § 3.)

8. Since then, the Trustee Defendants have claimed that WMBC Inc. is the successor-in-interest to WMBC and that WMBC no longer exists as an unincorporated association. (See Compl. ¶¶ 25–28, 41.) For example, in the Interpleader Action, they moved to have WMBC Inc. substituted as a party in WMBC’s place. The trial court in that action denied the motion and concluded that both WMBC and WMBC Inc. were necessary parties to determine the rights to the bank accounts. (See ECF No. 18.10.) The Trustee Defendants appealed that decision to the North Carolina Court of Appeals (No. 20-335), arguing, among other things, that the Interpleader Action violated the Trustee Defendants’ First Amendment rights to be free from ecclesiastical entanglement.

9. While that appeal was pending, McKnight and Foster (“Plaintiffs”), as trustees of WMBC, brought this suit on its behalf. (See Compl. ¶¶ 1, 4.)1 They have asserted claims for breach of fiduciary duty, constructive fraud, and unjust enrichment against the Trustee Defendants and WMBC Inc. (“Defendants”). They seek, among other things, to void the transfers of the church’s real property to WMBC Inc. (See Compl. ¶ 30.) WMBC Inc. has counterclaimed for trade name infringement, conversion, and civil conspiracy. (See ECF No. 6.)

10. Defendants have filed a motion to dismiss the amended complaint. The motion has been fully briefed, and the Court held a hearing on 11 March 2021.

1 Originally, Leroy Jeffreys and Julius Montague were also plaintiffs, but they have voluntarily dismissed their claims. (ECF No. 42.) They remain counterclaim defendants.

11. After the hearing, the Court of Appeals issued its opinion in the Interpleader Action, dismissing the appeal as interlocutory and concluding that the Interpleader Action did not constitute impermissible ecclesiastical entanglement. See United Cmty. Bank v. Wakefield Missionary Baptist Church, 2021-NCCOA-89 (unpublished). Given the similarities of some of the issues to be litigated in this case, the Court invited supplemental briefing on the status of the Interpleader Action and the implications of the decision and reasoning of the Court of Appeals. (ECF No. 46.)

12. Defendants’ motion to dismiss is now ripe for resolution.

II.

ANALYSIS

13. Defendants seek to dismiss the amended complaint for lack of jurisdiction and for lack of merit. The Court begins with the jurisdictional issues because subject matter jurisdiction is the “indispensable foundation upon which valid judicial decisions rest, and in its absence a court has no power to act.” In re T.R.P., 360 N.C. 588, 590 (2006).

A. Subject Matter Jurisdiction 1. Standing 14. “Standing refers to whether a party has a sufficient stake in an otherwise justiciable controversy such that he or she may properly seek adjudication of the matter.” Am. Woodland Indus., Inc. v. Tolson, 155 N.C. App. 624, 626 (2002) (citation omitted). Defendants argue that Plaintiffs lack standing for three reasons.

15. First, Defendants argue that Plaintiffs are not trustees of WMBC and therefore do not have standing to sue on its behalf. (See Br. in Supp. 8–9, ECF No.

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