## Facts

- The Episcopal Church of the Good Shepherd in San Angelo held its property through a Texas nonprofit corporation formed as a condition of affiliation with the Diocese of Northwest Texas and the national Episcopal Church.
- The corporation’s governing documents recognized and adopted diocesan canons and became part of the national church structure.
- In 1979, the national Episcopal Church adopted the “Dennis Canon,” stating that parish property is held “in trust” for the national church and the diocese while the parish remains affiliated.
- The Diocese conveyed the local church property to the parish corporation in 1982, placing record title in the corporation.
- After doctrinal disagreements, a majority of the congregation voted to amend corporate documents to remove references to the Episcopal Church and the Diocese, to withdraw from them, and to revoke purported trusts in their favor.
- The withdrawing faction affiliated with the Anglican Church in Uganda and continued to possess and use the property.
- The Diocese and a loyal faction sued for title and possession; the trial court granted summary judgment for the Diocese and loyal faction, and the court of appeals affirmed, approving a deference-based approach.

## Issues

1. Whether Texas courts must resolve church property disputes using a deference approach, a neutral-principles-of-law approach, or may choose between them.
2. Whether, applying the correct methodology, the Diocese and loyal faction proved entitlement to summary judgment on ownership and possession of the parish property.

## Decision

- The Supreme Court of Texas required Texas courts to apply only the neutral-principles-of-law methodology to church property disputes.
- The court rejected treating hierarchical church determinations as automatically dispositive of property rights when the dispute can be resolved through secular legal sources.
- Applying neutral principles to the summary-judgment record, the court held the Diocese and loyal faction were not entitled to summary judgment.
- The court reversed the court of appeals’ judgment and remanded to the trial court for further proceedings consistent with neutral-principles analysis.

## Legal Principles

- Texas courts must resolve church property disputes using neutral principles of law (e.g., deeds, corporate charters, articles, bylaws, and applicable statutes), while avoiding adjudication of doctrine or purely ecclesiastical polity.
- Civil courts defer to religious authorities on doctrinal and internal governance questions, but property ownership is determined through objective legal instruments when possible.
- A denominational canon declaring a trust in church property does not, by itself, conclusively establish an enforceable trust under Texas law; enforceability depends on state trust, property, and corporate law.
- Summary judgment is improper when the movant’s neutral-principles showing does not conclusively establish ownership as a matter of law on the record presented.

## Conclusion

The Supreme Court of Texas mandated neutral-principles analysis as the exclusive state-law method for church property disputes and held that the Diocese and loyal faction failed to establish, on the summary-judgment record, a conclusive legal right to the parish property, requiring reversal and remand for further proceedings.


Masterson v. Diocese of Nw. Tex., 422 S.W.3d 594 (Tex. 2013)