## Facts

- Two deeds conveyed West Virginia church property to trustees of the Gilboa Church of God, a local congregation associated with the Church of God (Anderson, Indiana).
- Each deed included a clause providing that if the property fell into disuse, or if “in the opinion of [the] General Ministerial Assembly” the local church was no longer “in fellowship and doctrinal unity” with the Church of God, title would vest in fee simple in the Board of Church Extension and Home Missions of the Church of God, Inc. (the Board).
- A pastor assumed leadership of the Gilboa congregation, and the Board asserted the congregation had separated from the parent body’s fellowship and doctrine.
- The Board filed a civil action to enforce the deed clause and quiet title in itself.
- The trial court held the condition had occurred and vested title in the Board.
- The trustees appealed, arguing the General Ministerial Assembly had not made the determination required by the deeds.

## Issues

1. Whether a civil court may adjudicate a church-property dispute when resolution would require deciding whether a congregation remains “in fellowship and doctrinal unity” with a parent church.
2. Whether the deed condition transferring title to the Board could be satisfied without an expressed determination by the General Ministerial Assembly that the local church was no longer in fellowship and doctrinal unity.

## Decision

- The Supreme Court of Appeals of West Virginia reversed the trial court’s judgment for the Board.
- The court held that civil courts may not decide ecclesiastical questions such as doctrinal unity or fellowship status.
- Interpreting the deeds under secular rules, the court held the reverter depended on an “opinion” of the General Ministerial Assembly.
- Because the record did not show a determination by the General Ministerial Assembly that Gilboa was out of doctrinal unity or fellowship, the triggering condition did not occur.
- The case was remanded for proceedings consistent with the court’s ruling, leaving title with the trustees absent the required ecclesiastical determination.

## Legal Principles

- Under the First Amendment, civil courts lack authority to resolve disputes requiring determination of religious doctrine, faith, fellowship, or internal church status.
- Church-property disputes may be decided using neutral principles of law (e.g., deed interpretation) so long as the court does not decide doctrinal or ecclesiastical questions.
- When a deed assigns a determinative predicate (such as doctrinal disunity) to a specified church authority, a civil court’s role is limited to determining whether that authority acted as the instrument requires.
- A condition in a deed that divests title upon a specified church body’s “opinion” is not satisfied by a civil court’s independent assessment of doctrinal separation.

## Conclusion

The court enforced the deed’s allocation of authority to the General Ministerial Assembly and held that, absent the Assembly’s determination of doctrinal disunity, the property did not revert to the Board and civil courts could not supply the missing ecclesiastical judgment.


Bd. of Church Extension & Home Missions of the Church of God, Inc. v. Eads, 159 W. Va. 943, 230 S.E.2d 911 (W. Va. 1976)