Iglesia Evangelica Latina, Inc. v. Southern Pacific Latin American Dist. of the Assemblies of God

Appellants Juan A. Reyes and Iglesia Evangélica Latina, Inc. (IEL), appeal the trial court’s judgment in favor of Southern Pacific Latin American District of the Assemblies of God (SPLAD) on three consolidated actions arising out of SPLAD’s takeover of IEL after an internal dispute at IEL and SPLAD’s transfer of IEL’s real property. Appellants contend that although DEL was affiliated with the national hierarchical church Assemblies of God, of which SPLAD was an intermediate governing body, SPLAD had no authority to take over its corporate governance and transfer its property to itself. We reverse the trial court’s judgment and hold in favor of DEL on SPLAD’s claims as well as IEL’s claims arising from the wrongful transfer of its property to SPLAD, and remand for a new trial on DEL’s remaining claims.

FACTUAL BACKGROUND AND PROCEDURAL HISTORY

The First Amendment prohibits civil courts from resolving church property disputes on the basis of religious doctrine and practice, and requires civil courts to defer issues of religious doctrine or polity to the highest court of a hierarchical church organization. While state secular courts may resolve church property disputes…