Schismatic and Purported Casa Linda Presbyterian Church America v. Grace Union Presbytery

This case concerns a dispute over the ownership of church property after some of the members of the Casa Linda Presbyterian Church of Dallas, Texas, sought to withdraw from the Presbyterian Church in the United States (PCUS), the hierarchical and parent church to which Casa Linda Presbyterian Church had always belonged. The withdrawing group appeals the trial courts judgment vesting title to the churchs real and personal property in the church members who remain loyal to the parent church. In seven points of error, the withdrawing group contends that the trial court erred by (1) violating the first and fourteenth amendments of the United States Constitution in failing to apply neutral principles of law to determine church ownership; (2) holding that the hierarchy of the PCUS was authorized to designate the minority of the membership of the Casa Linda Presbyterian Church of Dallas, Texas, as titleholder of all church property; and (3) and (4) finding that the hierarchy in fact designated the loyal group as such titleholder and finding null and void the meeting resulting in the withdrawing groups disaffiliation with the PCUS because neither finding is supported by legally or factually sufficient evidence; (5) basing the judgment on an implied trust theory, if it did, because such theory is without support in the law or evidence and was waived by appellees; (6) basing its judgment on the withdrawing groups violation of the "Pastoral Letter," if it did, because any such violation could not in effect divest title to the church property from the withdrawing group nor vest title in the loyal group; and (7) awarding the church property to "Casa Linda Presbyterian Church, Inc.," a nonexistent corporation. We do not agree that these points of error require reversal of the judgment. However, we modify the judgment to decree title in the Casa Linda Presbyterian Church or Dallas, Texas. As modified, we affirm.