NAHMIAS, Justice.
We granted certiorari in this case to consider whether the Court of Appeals correctly applied the “neutral principles of law” doctrine set forth in Jones v. Wolf, 443 U. S. 595, 602-606 (99 SC 3020, 61 LE2d 775) (1979), to this hierarchical church property dispute. See Timberridge Presbyterian Church, Inc. v. Presbytery of Greater Atlanta, Inc., 307 Ga. App. 191 (705 SE2d 262) (2010). Timberridge Presbyterian Church (“Timberridge”) is located on property owned by appellee Timberridge Presbyterian Church, Inc. (“TPC Inc.”), a corporation formed to hold and control the property of Timberridge. The Court of Appeals held that TPC Inc. did not hold the property in trust for the benefit of the Presbyterian Church (U.S.A.) (“PCUSA”), which is represented in this case by appellant Presbytery of Greater Atlanta, Inc. (“Presbytery”), the PCUSA’s governing body for the geographic district in which Timberridge is located. For the reasons that follow, we reverse.
1. Timberridge was formed in Henry County in 1830. In 1880, Timberridge became a member of the Presbyterian Church in the United States (“PCUS”), which was the southern branch of the post-Civil War denomination. The PCUS Book of Church Order (“BOCO”) set forth the rules governing the southern church. By early 1982, and apparently well before then, the northern and southern branches of the Presbyterian Church were meeting to discuss reunification, and the PCUS was meeting to consider whether to add a provision to its Book of Church Order stating that local churches hold their property in trust for the PCUS.
At a January 26, 1982, meeting of the Presbytery of Atlanta, the immediate predecessor of the Presbytery of Greater Atlanta, to consider and vote on constitutional amendments to the Book of Church Order, including the property trust provision, the participants included Timberridge’s pastor and one of its elders. The record does not reveal how they voted, but it shows that the property trust provision was approved by a vote of 155 for and 96 against. In June 1982, the General Assembly of the PCUS adopted the property trust provision. The provision stated that “[a] 11 property held by or for a particular [local] church, whether legal title is lodged in a corporation, a trustee or trustees, or an unincorporated association, ... is [273]*273held in trust. . . for the use and benefit of the [PCUS].” BOCO § 6.3. About two weeks later, the Presbytery of Atlanta met to vote on the reunification of the southern and northern branches of the Presbyterian Church. Timberridge’s pastor and an elder again attended. The vote was 235 for reunification and 54 against; an affidavit by Timberridge’s pastor states that he voted in favor of reunification.
In 1983, the PCUS and the northern branch of the denomination formally reunited as the Presbyterian Church (U.S.A.), and Timber-ridge became a member of the PCUSA. The PCUSA Book of Order (“BOO”), which took effect immediately upon the formation of the reunited church, sets forth the rules governing the national church and its local member (“particular”) churches. The Book of Order provides that “[t]he government of the church is representative,” BOO § G-6.0107, and that the PCUSA “shall be governed by representative bodies,” which in order from lowest to highest are called “session, presbytery, synod, General Assembly,” § G-9.0101. Each of those bodies is composed of presbyters (the elders and ministers of the particular churches), see id. and § G-4.0301 (b); is governed by majority vote, see § G-4.0301 (e); and “shall participate through its representatives in the planning and administration of the next higher body,” § G-9.0404 (a). A higher governing body has “the right of review and control” over decisions of lower ones. § G-4.0301 (f). As these provisions demonstrate, the PCUSA operates as a representative democracy, as has historically been the case with Presbyterian churches. See § G-1.0400 & n. 6.
Chapter 8 of the Book of Order contains the provisions of the church constitution governing property. Mirroring Section 6.3 of the PCUS Book of Church Order adopted the year before reunification, Section G-8.0201 of the BOO is an explicit trust provision, specifying that “[a]ll property held by or for a particular church ... , whether legal title is lodged in a corporation, a trustee or trustees, or an unincorporated association,... is held in trust nevertheless for the use and benefit of the [PCUSA].” Section G-8.0301 provides that if a local church stops using its property as a church of the PCUSA, the property “shall be held, used, applied, transferred, or sold as provided by the presbytery.” Section G-8.0601 similarly provides that, in the event of a schism within the membership of a local church,
the presbytery shall determine if one of the factions is entitled to the property because it is identified by the presbytery as the true church within the Presbyterian Church (U.S.A.). This determination does not depend upon which faction received the majority vote within the particular church at the time of the schism.
[274]*274Section G-8.0701 of the Book of Order permitted a local church, within eight years of the formation of the PCUSA, to opt out of a property provision of the BOO, but only if the local church was not “subject to a similar provision of the Constitution of the church of which it was a part” before the formation of the PCUSA. In addition, the PCUSA’s Articles of Agreement, which set forth the contractual agreement for reunification between the northern and southern branches, provided that a local church of either branch could petition for dismissal from the PCUSA for eight years after the reunion and if two-thirds of the congregation voted for dismissal, the local church would be dismissed and would retain all of its property. See Articles 13.3 (e), (g), 13.4.
The 1983 Book of Order also provided that, “[wjhenever permitted by civil law, each particular church shall cause a corporation to be formed” to “receive, hold, encumber, manage, and transfer property, real or personal, for the church.” §§ G-7.0401, G-7.0402. As required by these provisions, in 1984 Timberridge Presbyterian Church, Inc. was formed as a Georgia non-profit corporation to hold and control the property of Timberridge Presbyterian Church. TPC Inc.’s Articles of Incorporation state that the corporation’s purpose is “to be a church institution which is a member of the Presbytery of Atlanta of the [PCUSA] or any successor Presbytery thereof” and that its bylaws cannot conflict with the PCUSA Book of Order “as the same now exists or may hereafter from time to time be amended.” The Articles also provide that the corporation has the power to “receive, hold, encumber, manage, and transfer property, real and personal,” for the church, and that the corporation’s members will consist of “active members” of Timberridge as defined by the PCUSA Book of Order. Section G-5.0202 of the BOO provides that “an active member of a particular church is a person . . . [who] has voluntarily submitted to the government of [the PCUSA].”
Until 1970, the land on which Timberridge is located was owned by individuals who were also members of the church. From 1970 through 1987, the individual owners conveyed their various interests in the land to Timberridge and “its successors,” to Timberridge and its “heirs and assigns,” or simply to Timberridge without any successors or assigns language. During the eight years after reunification, Timberridge did not seek to retain all of its property by petitioning for dismissal from the PCUSA as allowed by the Articles of Agreement. However, in November 1987, following a vote of its congregation, Timberridge sent the Presbytery a letter stating that Timberridge had “voted to take the ‘property exemption’ as provided in the Book of Order, Section G-8.0700.” Timberridge did not receive a response to this letter from the Presbytery or the PCUSA. In 1999, Timberridge transferred all of its real property by warranty deeds to [275]*275TPC Inc. and “its successors, heirs, executors, administrators, and assigns in fee simple.”
For almost a quarter-century after Timberridge affiliated with the PCUSA in 1983, the local church functioned as a regular member of the national church. Its pastor from 1978 to 1984 stated that Timberridge “took part in the governance of the denomination by regularly attending meetings of the Atlanta Presbytery” and “experienced benefits of being associated with the [PCUSA] such as participation in the representational governance .. . and the availability of the denomination’s resources.” Similarly, Timberridge’s pastor from 1984 to 2003 stated that the church “actively participated in the governance of the denomination” and “experienced some of the benefits of being associated with the greater denomination, such as locating an Associate Pastor with the help of the [Presbytery] ... [and] taking advantage of . . . [a] year round camp and conference center.”
By 2007, however, a dispute arose between TPC Inc. and the Presbytery and PCUSA as to who controls Timberridge’s property. In September 2007, TPC Inc. filed an action for declaratory judgment and injunctive relief against the Presbytery, seeking a declaration that TPC Inc. owned all Timberridge property and did not hold it in trust for the benefit of the PCUSA. TPC Inc. later amended its complaint to add a quiet title action. The Presbytery filed a counterclaim, contending that TPC Inc. held the church property in trust for the benefit of the PCUSA and should be enjoined from transferring the property. In November 2007, a majority of the Timberridge congregation voted to disaffiliate from the PCUSA. In January 2008, the Presbytery filed an ejectment action against the majority faction identifying itself as Timberridge. Five months later, the majority faction of Timberridge affiliated with the Evangelical Presbyterian Church, a separate denomination.
The parties filed cross-motions for summary judgment, and on March 9, 2009, the trial court entered two separate but almost identical orders in the 2007 and 2008 lawsuits. Applying the neutral principles of law doctrine, the court concluded, among other things, that Section G-8.0201 of the Book of Order created a trust in favor of the PCUSA as to any property held by TPC Inc. The court also concluded that the opt out provision of Section G-8.0701 was of no avail to TPC Inc. with respect to the trust issue, because Timber-ridge was already “subject to a similar provision of the Constitution of the [general] church of which it was a part” before the formation of the PCUSA — the explicit property trust provision of the PCUS Book of Church Order. The court therefore granted summary judgment to the Presbytery in both actions. TPC Inc. filed appeals of both orders in this Court, which we transferred to the Court of Appeals [276]*276after finding that the appeals did not come within our equity or title to land jurisdiction. See Case Nos. S09A1494, S09A1495 (Apr. 12, 2010); Ga. Const, of 1983, Art. VI, Sec. VI, Par. Ill (1), (2).
The Court of Appeals reversed the trial court’s judgments. It weighed the neutral principles — the relevant deeds, state statutes, and local and national church documents — together, saying that the national church documents could not be dispositive. See Timberridge, 307 Ga. App. at 193. Instead, the court focused on whether the evidence established an express trust under OCGA § 53-12-20. See Timberridge, 307 Ga. App. at 200-201. The court concluded that,
[r]ead as a whole in light of the relevant law, the evidence is inadequate to show the existence of a trust in favor of the Presbytery. The evidence must reveal that “factors other than mere connectional relationship between a local and general church were present.” In the absence of some showing of intention and assent on the part of Timberridge, neutral principles of law cannot support the unilateral imposition of a trust provision drafted by the purported beneficiary of the trust and the resulting deprivation of the opposing party’s property rights.
Id. at 200 (citation omitted). This Court then granted certiorari.
2. To avoid First Amendment concerns in resolving property disputes in hierarchical religious denominations, secular courts apply “neutral principles of law” to determine whether the local church or the parent church has the right to control local property, avoiding any inquiry into religious doctrine. See Jones, 443 U. S. at 602-606.1 These “neutral principles” include relevant deeds, state statutes, and the governing documents of the local and general churches. See Jones, 443 U. S. at 602-606 (discussing the “corporate charter” of the local church and the “constitution of the general church”); Georgia Dist. Council of the Assemblies of God, Inc. v. Atlanta Faith Mem. Church, Inc., 267 Ga. 59, 60-61 (472 SE2d 66) (1996) (reviewing the bylaws of the denomination); Crumbley v. Solomon, 243 Ga. 343, 343-344 (254 SE2d 330) (1979) (reviewing the Disciplinary Rules of the parent church); Carnes v. Smith, 236 Ga. 30, 37 (222 SE2d 322) (1976) (reviewing the Book of Discipline of the parent church and noting that the corporate charter of the local church would have been relevant if the local church had one). We review all of these materials, keeping in mind that the outcome of these church property disputes usually turns on the specific facts [277]*277presented in the record, that the neutral principle factors are interrelated, and that our ultimate goal is to determine “the intentions of the parties” at the local and national level regarding beneficial ownership of the property at issue as expressed “before the dispute erupt[ed]” in a “legally cognizable form.” Jones v. Wolf, 443 U. S. at 603, 606.
(a) Deeds
The deeds that transferred the property at issue from the individual owners to Timberridge between 1970 and 1987 do not contain trust language. The 1999 deeds then transferred the property from Timberridge to TPC Inc. and “its successors, heirs, executors, administrators, and assigns in fee simple.” The Court of Appeals held that the “absence of any trust language in the deeds” weighed against the recognition of a trust in favor of the PCUSA. Timberridge, 307 Ga. App. at 196. We disagree.
It is true that neither the 1970-1987 deeds nor the 1999 deeds show an intent by the grantors to create a trust. But they also do not expressly preclude the creation of one. And it is undisputed that Timberridge affiliated with the PCUSA in 1983 and thus brought itself under the national church’s constitution, which squarely states that local churches such as Timberridge hold their property in trust for the PCUSA even if “legal title is lodged in a corporation.” Given that provision, Timberridge would have no reason to believe that its deeds needed to recite a trust in favor of the general church, particularly the 1999 deeds transferring the property at issue to TPC Inc. Thus, the absence of language in the deeds creating a trust in favor of the national church is of limited value in deciding the question before us, and we turn to consideration of other neutral principles.
(b) Statutes
(1) OCGA § 14-5-46
OCGA § 14-5-46, which is entitled “Conveyances to churches or religious societies confirmed,” provides:
All deeds of conveyance executed before April 1, 1969, or thereafter for any lots of land within this state to any person or persons, to any church or religious society, or to trustees for the use of any church or religious society for the purpose of erecting churches or meeting houses shall be deemed to be valid and available in law for the intents, uses, and purposes contained in the deeds of conveyance. All lots of land so conveyed shall be fully and absolutely vested in such church or religious society or in their respective trustees for the uses and purposes expressed in the deed to be held by them or their trustees for their use by succession, [278]*278according to the mode of church government or rules of discipline exercised by such churches or religious societies.2
This Court has repeatedly applied this statute and its predecessors, including Code Ann. § 22-5507, to church property disputes. See, e.g., Holiness Baptist Assn. v. Barber, 274 Ga. 357, 358-359 (552 SE2d 90) (2001); Crumbley, 243 Ga. at 344-345; Carnes, 236 Ga. at 37-38. However, the Court of Appeals held that OCGA § 14-5-46 could not be applied here to support the creation of a trust because “the deeds ... do not convey the property to trustees, nor to the Presbytery or PCUSA, but simply to ‘Timberridge Presbyterian Church’ or ‘Timberridge Presbyterian Church, Inc.’ ” Timberridge, 307 Ga. App. at 194.
By its plain language, OCGA § 14-5-46 applies (1) if there is a deed “to any person or persons,” “to any church or religious society,” or “to trustees” for the use of any church and (2) if the deed is “for the purpose of erecting churches or meeting houses.” Thus, the statute is not limited to deeds to trustees or that contain trust language, and indeed this Court applied OCGA § 14-5-46 to a deed that did not contain any trust language in Barber. See 274 Ga. at 358-359. There, the deed conveying the local church property was simply “to named individuals as ‘Deacons of Vickers Holiness Baptist Church [the local church] and their successors in office.’ ” Id. at 359, n. 7. Citing OCGA § 14-5-46, we held that
it is undisputed that the Association [the general church] remains a hierarchy, that the [local] Church has been a member of the Association for over 30 years, and that the Church is subject to the Association’s discipline. Such discipline unquestionably provides that the Association “shall hold all church property,” thereby implying a trust for the benefit of the Association.
Barber, 274 Ga. at 359 (citations and footnotes omitted).
Although the Court of Appeals’ reason for not applying OCGA § 14-5-46 was erroneous, we note that this Court and the Court of Appeals have failed to analyze another component of the statutory text in our modern cases, namely, whether the property was con[279]*279veyed “for the purpose of erecting churches or meeting houses.” See, e.g., Barber, 274 Ga. at 358-359; Crumbley, 243 Ga. at 344-345; Carnes, 236 Ga. at 37-38; Rector &c. of Christ Church v. Bishop of the Episcopal Diocese of Ga., 305 Ga. App. 87, 90-92 (699 SE2d 45) (2010), aff'd 290 Ga. 95 (718 SE2d 237) (2011). Compare Harris v. Brown, 124 Ga. 310, 314 (52 SE 610) (1905) (holding that OCGA § 14-5-46’s predecessor applied only to deeds conveying property for the purpose of erecting a church building and therefore did not apply to the deed in question, which conveyed property for the purpose of erecting both church and school buildings).
Instead, we appear to have viewed OCGA §§ 14-5-46, 14-5-47, and their predecessors, which date back more than two centuries, see Ga. Laws 1805, pp. 15-16, as expressing this State’s policy of looking to “the mode of church government or rules of discipline” in resolving church property disputes, even when the statutory text does not squarely apply. This policy is consistent with Jones v. Wolf's focus on local and parent church governing documents as an important neutral principle. See 443 U. S. at 602-606. See, e.g., Barber, 274 Ga. at 359; Carnes, 236 Ga. at 38 (stating broadly that “Code Ann. § 22-5507 [now OCGA § 14-5-46] recognizes and validates deeds conveying land for church purposes according to the limitations set out in the deed and for use ‘according to the mode of church government or rules of discipline’ ”). In any event, although OCGA § 14-5-46 may weigh in favor of the trial court’s judgments under our precedents, we need not rely on it to resolve this case.
(2) OCGA § 53-12-20
Instead of focusing on OCGA § 14-5-46, the Court of Appeals relied heavily, and incorrectly, on Georgia’s generic express trust statute. OCGA § 53-12-20 provides, in relevant part, as follows:
(a) [A]n express trust shall be created or declared in writing and signed by the settlor ....
(b) An express trust shall have, ascertainable with reasonable certainty:
(1) An intention by a settlor to create such trust;
(2) Trust property;
(3) Except for charitable trusts,... a beneficiary who is reasonably ascertainable at the time of the creation of such trust or reasonably ascertainable within the period of the rule against perpetu-ities;
(4) A trustee; and
[280]*280(5) Trustee duties specified in writing or provided by law.
The Court of Appeals effectively held that local and national church documents cannot suffice to establish a trust in favor of the national church without compliance with this statute. The court concluded that the church documents in this case could not create a trust in favor of the PCUSA because they were not “sufficient to establish an express trust” since they did not “show ‘with reasonable certainty’ an intention on the part of Timberridge to create an express trust, OCGA § 53-12-20 (b).” Timberridge, 307 Ga. App. at 200.
Requiring compliance with OCGA § 53-12-20, however, would be inconsistent with the teaching of Jones v. Wolf that the burden on a national church and its member churches to provide which one will control local church property in the event of a dispute will be “minimal.” 443 U. S. at 606. In this regard, the dissenters in Jones expressed concern that the neutral principles doctrine would unconstitutionally interfere with the free exercise rights “of those who have formed the association and submitted themselves to its authority.” Jones, 443 U. S. at 618 (Powell, J., dissenting).
The Court rejected that concern in this important passage:
Nothing could be further from the truth. The neutral-principles approach cannot be said to “inhibit” the free exercise of religion.... Under the neutral-principles approach, the outcome of a church property dispute is not foreordained. At any time before the dispute erupts, the parties can ensure, if they so desire, that the faction loyal to the hierarchical church will retain the church property. They can modify the deeds or the corporate charter to include a right of reversion or trust in favor of the general church. Alternatively, the constitution of the general church can be made to recite an express trust in favor of the denominational church. The burden involved in taking such steps will be minimal. And the civil courts will be bound to give effect to the result indicated by the parties, provided it is embodied in some legally cognizable form.
Jones, 443 U. S. at 606 (emphasis added).
As this passage explains, local churches can modify their deeds, amend their charters, or draft a separate legally recognized document to establish an express trust as set forth in OCGA § 53-12-20. But that is not the only way in which the parties can ensure that [281]*281local church property will be held in trust for the benefit of the national church; it may also be done through the national church’s constitution, for example, by making it “recite an express trust.” Jones, 443 U. S. at 606. If, as the Court of Appeals held in this case, hierarchical denominations must fully comply with OCGA § 53-12-20 for the parent church to retain control of local church property when there is a schism and a majority of the local church congregation disaffiliates, then an enormous number of deeds and corporate charters would need to be examined and re-conveyed or amended; the burden on the parent churches, the local churches that formed the hierarchical denominations and submitted to their authority, and the free exercise of religion by their members would not be minimal but immense.
Moreover, the Court of Appeals’ approach is inconsistent with this Court’s cases deciding that local churches held their property in trust for the general church with no mention of OCGA § 53-12-20 or evidence of compliance with its terms. See, e.g., Kemp v. Neal, 288 Ga. 324, 326-329 (704 SE2d 175) (2010) (plurality); id. at 331-334 (Carley, E J., dissenting in part); Barber, 274 Ga. at 358-359; Crumbley, 243 Ga. at 344-345; Carnes, 236 Ga. at 37-38. If compliance with OCGA § 53-12-20 were necessary to create a trust in favor of a national church, those cases could not have been decided as they were. We also note that our numerous church property cases either made no mention of the generic implied trust statutes, now OCGA §§ 53-12-90 to 53-12-93, see, e.g., Kemp, 288 Ga. at 326-329 (plurality); id. at 331-334 (Carley, E J., dissenting in part); Barber, 274 Ga. at 358-359; Crumbley, 243 Ga. at 344-345, or explained that the requirements of those statutes were not met, see Carnes, 236 Ga. at 37-38 — and yet the Court still concluded that the local church property was held in trust for the general church.
The Court of Appeals dismissed our precedent by saying that our cases did not “cite the express trust provisions . . . because these cases involved implied trusts.” 307 Ga. App. at 194-195 (emphasis added). But this case, like previous cases, involves a trust implied under neutral principles of law, even though one aspect of that analysis is consideration of trust language expressly included in the national church’s discipline. See, e.g., Barber, 274 Ga. at 359 (“implying a trust” for the benefit of the general church where its discipline expressly provided that the general church “shall hold all church property”).
In short, and contrary to the Court of Appeals’ decision, the fact that a trust was not created under our state’s generic express (or implied) trust statutes does not preclude the implication of a trust on church property under the neutral principles of law doctrine. See Kemp, 288 Ga. at 326-329 (plurality); Barber, 274 Ga. at 358-359; [282]*282Crumbley, 243 Ga. at 344-345; Carnes, 236 Ga. at 37-38. Accord Bishop and Diocese of Colorado v. Mote, 716 P2d 85,100 (Colo. 1986) (explaining that Jones v. Wolf “did not restrict the inquiry to a search for explicit language of express trust” (emphasis in original)).
(c) Church Governing Documents
(1) Local Church Documents
It is clear that Timberridge formed TPC Inc. in 1984 because Section G-7.0401 of the governing Book of Order adopted with the PCUSA’s formation in 1983 required all member churches to form a corporation to hold and control church property if permitted by their state law. TPC Inc.’s Articles of Incorporation filed with the Georgia Secretary of State unequivocally submit Timberridge and its property to the PCUSA as its governing authority. The Articles provide that the corporation is “to be a church institution which is a member of the Presbytery of Atlanta of the [PCUSA], or any successor Presbytery thereof.” Indeed, the corporation’s members must be “active members” of Timberridge “as defined in the Book of Order of the [PCUSA],” which defines an “active member of a particular church” to be a person who has “voluntarily submitted to the government of this [general] church.” BOO § G-5.0202. Thus, the corporation’s charter precludes any TPC Inc. member who refuses to submit to the government of the PCUSA from continuing to function as a member of TPC Inc.3
In addition, TPC Inc.’s Articles of Incorporation state that its bylaws cannot conflict with the PCUSA Book of Order. A corporation’s “ £[b]ylaws’ means the code of rules other than the articles [of incorporation] adopted pursuant to this chapter for the regulation or management of the affairs of the corporation . . . .” OCGA § 14-3-140 [283]*283(4). See also OCGA § 14-5-40 (providing that Chapter 3 of Title 14 is applicable to nonprofit corporations formed for religious purposes). As discussed in Division 1 above, the Book of Order provides comprehensive rules regarding the government of a local church, its relationship to the Presbytery and the PCUSA, and its property — including an explicit provision stating that “[a]ll property held by or for a particular church .. ., whether legal title is lodged in a corporation, a trustee or trustees, or an unincorporated association, ... is held in trust nevertheless for the use and benefit of the [PCUSA].”
The Court of Appeals erroneously concluded that TPC Inc.’s charter sheds no light on the trust issue, saying the Articles of Incorporation “do not express such clear intent to render the local church corporation subject in all matters both ecclesiastical and temporal to the authority of the Presbytery or PCUSA.” Timberridge, 307 Ga. App. at 196-197. It may be that TPC Inc. did not render itself subject to the authority of the PCUSA and Presbytery in all temporal matters (and courts should pay no attention to ecclesiastical matters). But TPC Inc. holds legal title to the local church’s property and its founding document plainly makes the local church subject to the PCUSA Book of Order, which contains a very explicit trust provision. And under the corporate charter and the Book of Order, any effort by TPC Inc. or its putative members to break away from the PCUSA results in the individuals no longer being members of the corporation and the property reverting to the control of the Presbytery. See BOO §§ G-8.0301, G-8.0601. By adopting these Articles of Incorporation, TPC Inc., with unmistakable clarity, agreed to bind itself to the Presbytery and the PCUSA and to abide by the Book of Order, which has included the explicit property trust and other governance provisions since the PCUSA was established in 1983 — well before Timberridge transferred the property at issue in this case to TPC Inc. in 1999.
Presiding Justice Carley’s dissent notes that Article X allows amendment of the Articles of Incorporation and does not expressly prohibit an amendment from conflicting with the Book of Order. See Dis. Op. at 292. The dissent says that this “necessarily” means that TPC Inc. “is not subject to the Book of Order or its trust provision.” Id. But it means no such thing. As a matter of law, articles of incorporation bind a corporation and its members until the document is properly amended. What is relevant about the Articles of Incorporation is that in its own charter TPC Inc. proclaimed its allegiance to the PCUSA Book of Order, which included a provision explicitly stating that local church property is held in trust for the use and benefit of the PCUSA, and at no time during the more than two decades before this dispute erupted and the eight years after it was deeded the property at issue did TPC Inc. even seek to amend its [284]*284Articles to demonstrate any different intent.
(2) National Church Documents
Timberridge joined the PCUSA when the reunited national church was established in 1983. There is no dispute that at that time (1) the PCUSA’s governing constitution plainly stated that local churches hold their property in trust for the use and benefit of the general church, see BOO § G-8.0201, and (2) the governing constitution of the general church that Timberridge had previously belonged to, the PCUS, contained an identical trust provision, see BOCO § 6.3. Moreover, when Timberridge affiliated with the PCUSA, it agreed that it “was a local expression of the universal church,” BOO § G-4.0102, that it would be “governed by this Constitution,” § G-4.0104, that its active members have “voluntarily submitted to the government of this church,” § G-5.0202, and that it would “function under the provisions of this Constitution.” § G-7.0101. Timberridge then had the right to leave the PCUSA for eight years, taking its property with it, see Article 13 of PCUSA Articles of Agreement, but instead it stayed. And while Timberridge purported to opt out of the property provisions of the Book of Order pursuant to its November 1987 letter to the Presbytery, it plainly could not opt out of the property trust provision in Section G-8-0201, which mirrored the one in Section 6.3 of the PCUS Book of Church Order. See BOO § G-8.0701 (stating that a local church could opt out of a property provision of the BOO within eight years of the formation of the PCUSA only if the local church was not “subject to a similar provision of the Constitution of the church of which it was a part” before the PCUSA was formed).4
Thus, contrary to the Court of Appeals’ view that the PCUSA “unilateral[ly] impos[ed]” the trust provision without any assent by the local church, see 307 Ga. App. at 200, Timberridge’s act of affiliating with the PCUSA in 1983 with the trust provision already in its governing constitution demonstrated that Timberridge assented to that relinquishment of its property rights — rights it then [285]*285chose not to reassert by leaving the new national church during the next eight years. The creation of TPC Inc. in 1984 and the transfer of Timberridge’s property to that corporate entity in 1999 further demonstrated Timberridge’s acceptance of the trust provision, as discussed in the last subdivision. And Timberridge’s continued membership in the PCUSA, for nearly a quarter of a century in all, with the trust provision always in full effect, further bolsters this conclusion. See Barber, 274 Ga. at 359; Crumbley, 243 Ga. at 345.
For these reasons, in considering the national church’s constitution in this case, we need not address the more difficult question of whether a general church may amend its governing documents, pursuant to procedures agreed upon by it and its member churches, to add an explicit property trust provision and make that trust apply to the property of its existing members, particularly where the evidence does not indicate that the national church historically had authority over local church property. See Kemp, 288 Ga. at 331-332 (Carley, P J., dissenting in part).5 However that question is resolved, it may be incorrect to characterize such an amendment as the “unilateral imposition of a trust provision,” as the Court of Appeals did here, see 307 Ga. App. at 200, if the national church enacted the trust provision pursuant to rules of representative government that the local and national churches previously agreed to follow, see BOO §§ G-4.0104, G-7.0101, and in which the local church’s representatives could and did participate. We also need not address TPC Inc.’s contention that the procedures used by the PCUS and the PCUSA to adopt the property trust provisions of the Book of Church Order and the Book of Order were flawed. See Rector &c. of Christ Church, 305 Ga. App. at 97 (holding that the First Amendment precludes a court from “questioning the validity of the process by which the church legislates”); Episcopal Church Cases, 198 P3d 66, 80 (Cal. 2009) (same), cert. denied,_U. S__(130 SC 179, 175 LE2d 41) (2009).
Our conclusion regarding the effect of the local and national church documents in this case is consistent with the precedent of the United States Supreme Court, this Court, and many state courts. The decisions from other states on which Presiding Justice Carley’s [286]*286dissent principally relies are readily distinguishable6 or wrongly decided,7 and Judge Benefield’s dissent cites no precedent that supports her position.8
[287]*287Finally, we reject Judge Benefield’s assertion that the neutral principles doctrine, and particularly its consideration of church governing documents, “creates a bias for the national church.” Dis. Op. at 299. Before Jones v. Wolf, courts normally resolved property disputes in hierarchical denominations simply by deferring to the decision of the general church’s ecclesiastical authorities. See Watson v. Jones, 80 U. S. 679, 726-729 (20 LE 666) (1871). That approach was “biased” toward the national church — and it should be noted that the four Justices who dissented in Jones v. Wolf did not suggest that the neutral principles doctrine was insufficiently fair to local churches but instead wanted to continue simply to defer to the general church to avoid First Amendment concerns. See 443 U. S. at 620-621 (Powell, J, dissenting).
The neutral principles doctrine, as approved by the majority in Jones v. Wolf and as applied by this Court, allows hierarchical denominations to structure the property relationships between the general and local churches before disputes arise. The result is not pre-ordained; it depends on the deeds, statutes, and national and church governing documents. What has happened over the years since Jones v. Wolf is that many hierarchical denominations have added more explicit property provisions to their general and local church governing documents, as the Supreme Court said would be appropriate. See 443 U. S. at 606. Thus, instead of our finding no mention of property issues in those documents, see Jones II, 244 Ga. at 389-390 (finding no trust for the general church where review of the “corporate charters, relevant deeds, and the organizational constitutions of the denomination” found only “silence”), we find provisions showing either that the general church does not control local church property, see Georgia Dist. Council of Assemblies of God, 267 Ga. at 61 & n. 2, or, as in this case and others, provisions showing that local church property is held in trust for the general church. Applying the neutral principles with an even hand, we simply enforce the intent of the parties as reflected in their own governing documents; to do anything else would raise serious First Amendment concerns.
3. Conclusion
In sum, the resolution of this church property dispute in the national church’s favor does not rest on the “mere connectional relationship between a local and general church.” Carnes, 236 Ga. at [288]*28835. Instead, our decision derives from the specific language of the governing documents adopted by the local and national churches, supported by the policy reflected in OCGA § 14-5-46 and not contradicted by the deeds at issue. It is based, therefore, on the sort of legal materials “familiar to lawyers and judges,” embodied in “legally cognizable form,” and having nothing to do with the church’s religious doctrine. Jones v. Wolf, 443 U. S. at 603, 606. Like the trial court, we conclude that neutral principles of law demonstrate that an implied trust in favor of the PCUSA exists on the local church’s property to which TPC Inc. holds legal title. See Barber, 274 Ga. at 359; Crumbley, 243 Ga. at 345. The Court of Appeals erred in concluding to the contrary.
Judgment reversed.
Benham, Thompson, and Melton, JJ., concur. Hunstein, C. J., Carley, E J., and Chief Judge Deborah C. Benefield dissent. Hines, J., not participating.