147 So. 3d 25
Fla. Dist. Ct. App.2013Background
- NJC, Inc. is a hierarchical church with a mother church in Orlando and local churches whose pastors are appointed by NJC, Inc., governed by The Book of Rules.
- The Book requires local property to be held in trust by NJC, Inc. with deeds containing a trust clause and subject to NJC, Inc.'s doctrines.
- NJC, Sneads, Florida acquired the property in 1966 via a deed that did not conform to the Book's requirements and naming issues existed about control.
- For decades, NJC, Sneads participated in NJC, Inc.'s activities, including conferences and financial contributions, suggesting ongoing affiliation.
- In 1997, the trustees conveyed the property to SCC as trustees of NJC of Sneads, Florida, without NJC, Inc.'s knowledge, creating a cloud on NJC, Inc.'s title.
- The trial court denied NJC, Inc.'s motions for directed verdict and JNOV, and the jury quieted title in SCC; on appeal, the court reverses.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether NJC, Inc. is a hierarchical church entitled to deference on ownership | NJC, Inc. is hierarchical; deference applies | SCC ownership should be recognized despite hierarchy | Yes; NJC, Inc. is hierarchical and controls property |
| Whether NJC, Sneads was affiliated with NJC, Inc. such that property belongs to NJC, Inc. | NJC, Sneads was affiliated for over 30 years | Affiliation was loose; not under NJC, Inc.'s umbrella | Yes; NJC, Sneads affiliated and property belongs to NJC, Inc. |
| Whether the trial court erred in denying directed verdict/JNOV on hierarchical ownership | Court must defer to NJC, Inc.'s self-characterization | Jury should decide factual affiliation, not the court | Reversed; directed verdict/JNOV in favor of NJC, Inc. |
Key Cases Cited
- Watson v. Jones, 80 U.S. (13 Wall.) 679 (U.S. Supreme Court 1871) (deference principle for hierarchical church disputes)
- Milivojevich, 426 U.S. 696 (U.S. Supreme Court 1976) (requires deference when ecclesiastical polity decisions are central)
- Mills v. Baldwin, 362 So.2d 2 (Fla. 1978) (Florida adopts deference approach to church property disputes)
- Falls Church v. Protestant Episcopal Church in the United States, 740 S.E.2d 540 (Va. 2013) (analogy to contractual relationship in hierarchical structure)
- Jones v. Wolf, 443 U.S. 595 (U.S. Supreme Court 1979) (neutral principles as alternative framework)