Aldersgate United Methodist Church of Montgomery, et al. v. Alabama-West Florida Conference of the United Methodist Church, Inc., et al., [Ms. SC-2023-0830, May 31, 2024] __ So. 3d __ (Ala. 2024). In a per curiam decision, (Bryan, J., concurs specially, which Mitchell, J., joins; Cook, J., concurs specially, which Parker, C.J., joins; Sellers, J., concurs in the result; Mendheim, J., concurs in the result; Shaw, Wise, and Stewart, JJ., recuse), the Court affirms the Montgomery Circuit Court’s dismissal of this action for lack of subject-matter jurisdiction under the Establishment Clause. A dispute arose between the Alabama-West Florida Conference (“the Conference”) of the United Methodist Church (“the UMC”), and 44 Methodist churches in the Conference (“the churches”). When the Conference denied the churches the right to vote to leave the UMC under a specially enacted provision of the governing law of the UMC, the churches sought relief in the Montgomery Circuit Court ordering the Conference to allow them to vote. Ms. *2.
The Court rejects the churches’ argument that the dispute involves only “civil and property issues” and explains “the churches’ central claims turn entirely on the interpretation of ¶ 2553 [of the Book of Discipline] and whether their efforts to leave the UMC were consistent with that church law.” Ms. *5.
While reiterating that “[t]he ‘neutral principles of law’ approach allows Alabama courts adjudicating church-property disputes to ‘consider, in purely secular terms, the language of the deeds, the charter of the local church, any applicable state statutes, and any relevant provisions contained in the discipline of the national church’ without running afoul of the First Amendment,” the Court notes “that doctrine has limits: when deciding such property disputes, civil courts ‘cannot resolve controversies involving religious doctrine or practice.’” Ms. *9, quoting Trinity Presbyterian Church of Montgomery v. Tankersley, 374 So. 2d 861, 865-66 (Ala. 1979), internal citation omitted.