Greater New Jersey Annual Conference of the United Methodist Church v. Borough of Stratford
000354-2024
N.J. Tax Ct.Jun 2, 2025Background
- The Greater New Jersey Annual Conference of the United Methodist Church (GNJUMC), a recognized religious organization, owned property in Stratford, New Jersey used as a church.
- The property was tax-exempt for 2022 and 2023, classified as church and charitable property, until questioned by the Borough’s assessor due to doubts about active religious use.
- In 2023, an added tax assessment was imposed after the Borough did not receive a required “Further Statement” and believed the property was not being actively used for religious purposes.
- GNJUMC claimed continued religious use, specifically storage of religious artifacts after church services ceased, and sought summary judgment to void the assessment.
- The Borough argued discovery was incomplete, particularly regarding facts about the property's use, and opposed summary judgment as premature.
- The court addressed only the 2023 tax year, denying summary judgment to allow discovery on the property's actual use.
Issues
| Issue | GNJUMC's Argument | Borough's Argument | Held |
|---|---|---|---|
| Effect of missed Further Statement | Filing not required for exemption to continue | Exemption cannot continue without timely Further Statement | Court: Not a bar to exemption; procedural, not substantive |
| Whether property use qualified as exempt | Storage of religious artifacts is a religious use | Unclear if property actually used for exempt purpose | Discovery needed; summary judgment denied |
| Prematurity of summary judgment | Facts uncontested; entitled to relief now | Facts regarding use require discovery | Summary judgment premature; Borough entitled to discovery |
| Applicability of precedent (Red Bank) | No change in use/ownership means assessment improper | New facts about use warranted assessment | Red Bank not controlling; facts distinguishable |
Key Cases Cited
- Emanuel Missionary Baptist Church v. Newark City, 1 N.J. Tax 264 (N.J. Tax Ct. 1980) (failure to file statement does not defeat exemption)
- Schizophrenia Foundation of New Jersey v. Montgomery Twp., 6 N.J. Tax 439 (App. Div. 1984) (October 1 is key date for exemption status)
- Bethany Baptist Church v. Deptford Twp., 225 N.J. Super. 355 (App. Div. 1988) (exemption benefit ceases with change in use/ownership)