Presbytery of St. Andrew, Presbyterian Church U.S.A., Inc. v. First Presbyterian Church PCUSA of Starkville

First Presbyterian Church PCUSA of Starkville, Mississippi, (“FPC”) sought declaratory relief, a temporary restraining order, and injunctive relief against the Presbytery of St. Andrew Presbyterian Church U.S.A., Inc. (“Presbytery”), after the Presbytery claimed FPC’s property was held in trust for the Presbyterian Church in the United States of America (“PCUSA”). FPC has transitioned into and out of multiple Presbyterian denominations, including the Old School Presbyterian Church; the Presbyterian Church, Confederate States of America; and the Presbyterian Church in the United States (“PCUS”). In 1983, the PCUS merged with another Presbyterian denomination to create the Presbyterian Church in the United States of America (“PCUSA”). FPC has been affiliated with the PCUSA since its inception. FPC claimed that, although it was affiliated with several different Presbyterian denominations, it existed as an “independent, unincorporated religious association from its founding until 2003.” Following its incorporation, FPC conveyed to the corporation its main property and facility in Starkville. The titleholder of record was then identified as FPC’s corporate entity. Any property duly transferred to the corporation remains held by and titled in the name of First Presbyterian Church, Starkville, Mississippi. Prior to 1982, no official documents of the PCUS included trust language. After the PCUSA was formed, the Book of Order contained a trust clause, and local churches then were required to “obtain permission before selling, mortgaging, or otherwise encumbering the property of that particular church.” Because this new trust clause was a departure from prior practice, the PCUSA’s constitution allowed for a “property exception.” Due to increasing disagreement with the PCUSA, FPC voted to cease monetary contributions to the Presbytery and look at the possibility of joining another Presbyterian denomination. In response to schism in the membership of FPC, the Presbytery notified FPC that it had appointed a Presbytery committee, called an Administrative Commission, to “inquire into and settle difficulties” at FPC. FPC’s session passed a resolution authorizing the filing of a legal action to determine the property rights of FPC, the Presbytery, and the PCUSA. FPC sought a declaratory judgment recognizing FPC’s exclusive ownership of all property held by it or in its name, free of any trust claimed by the PCUSA. FPC also requested a temporary restraining order prohibiting the Presbytery from taking control or possession of FPC’s property or from interfering with FPC’s property ownership. The chancery court granted summary judgment in favor of FPC, finding no evidence of any trust, express or implied. After review, the Mississippi Supreme Court agreed and affirmed the finding of the chancery court. View "Presbytery of St. Andrew, Presbyterian Church U.S.A., Inc. v. First Presbyterian Church PCUSA of Starkville" on Justia Law