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Alabama Supreme Court Affirms Circuit Court's Dismissal for Lack of Subject Matter Jurisdiction Because the Dispute Turned on "Ecclesiastical Issues"

Aldersgate United Methodist Church v. Alabama-West Florida Conference of the United Methodist Church, Inc.

By Henry C. Sheils


In Aldersgate United Methodist Church of Montgomery v. Alabama-West Florida Conference of the United Methodist Church, Inc., the Alabama Supreme Court addressed whether the circuit court had jurisdiction to settle property disputes between local Methodist churches and their larger denomination through the interpretation of religious doctrine. Plaintiffs, a collection of forty-four local churches, argued that the Book of Discipline, the governing document of the United Methodist Church, Inc., (“UMC”), granted the local churches the right to vote on the matter of disaffiliation and retain their property in doing so. Affirming the Montgomery Circuit Court’s decision to dismiss the case, the Alabama Supreme Court concluded that civil courts lacked subject matter jurisdiction over the issue because the relief sought required the judicial interpretation of ecclesiastical issues.

In 2023, “Aldersgate United Methodist Church of Montgomery and forty-three other Methodist churches . . . sought to disaffiliate from the UMC because of their disapproval of the UMC’s acceptance of homosexuality and its ordination of gay clergy.” In 2019, amidst the growth of these concerns among its local churches, the UMC installed an exception to the existing rule that the UMC would retain a local church’s associated church property if that church chose to disaffiliate. This exception, enacted through ¶ 2335 of the Book of Discipline, allowed local churches to disaffiliate from the UMC while retaining their property if they were disaffiliating “for reasons of conscience” stem-ming from “the practice of homosexuality or the ordination or marriage of self-avowed practicing homosexuals . . . .” This exception was set to expire on December 31, 2023.7

The Alabama-West Florida Conference (“the Conference”) abruptly changed this disaffiliation process in June 2023. The adjusted process now required local churches to submit “eligibility statements” to the Conference, which were to list the local church’s “‘reasons of conscience’ regarding . . . actions or inactions by [the Conference] . . . .” The Conference “would then . . . decide whether to allow each church’s congregation to vote on disaffiliation under ¶ 2553.” Each of the churches submitted eligibility statements, but each statement was rejected by the Conference in September 2023 “as insufficient under ¶ 2553 . . .



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