In Powerhouse Ministries v. Friendly Church, the Fifth Court reversed a trial court’s judgment that awarded church property to a group of members who had left the original church and formed a new and independent entity.

The Court first held that ecclesiastical immunity didn’t apply to the trespass-to-try-title claim in the case. Then, the Court determined that the original church, which had changed its name to “Powerhouse,” was the same entity that had acquired the property over time through five deeds–while the new entity, which had adopted the name “Friendly,” had no claim to the property based on its name alone.

“[T]he fact that the entity later changed its name does not change the facts of its acquisition, possession, and operation of the Property,” said the Court, and “when the members of the Separated Friendly Church left the Original Friendly Church, they abandoned any claim to the Property.” No. 05-23-00824-CV (Aug. 27, 2024) (mem. op.).

An eccleastical-immunity dispute led to the denial of mandamus relief in In re Munger Avenue Baptist Church, in which the Court reminded: “[W]here the petition for writ of mandamus challenges the trial court’s subject matter jurisdiction over the underlying proceeding, relators need not establish the lack of an adequate appellate remedy.” No. 05-21-00539-CV (April 13, 2022).

The Fifth Court affirmed the dismissal, on ecclesiastical-abstention grounds, of a fraud claim about the handling of a sex-abuse claim by the Roman Catholic Diocese of Dallas: “The district court determined that (i) the Dallas Diocese’s Sexual Misconduct Policy (Policy) was ‘an outgrowth of, or so integrally related to, the Dallas Diocese’s dogma that it comprises part of the Dallas Diocese’s religious representations, beliefs, and teachings,’ (ii) Doe’s fraud claim required Doe to prove the Dallas Diocese’s material representations to Doe were false, and (iii) the First Amendment to the Constitution of the United States prohibited the trial court from adjudicating the truth or falsity of religious doctrines or beliefs. Because Doe’s claims require resolution of matters of church government, we affirm the judgment of the trial court.” Doe v. Roman Catholic Diocese of Dallas, No. 05-19-00997-CV (Aug. 11, 2021) (mem. op.).

The Fifth Court found that ecclesiastical abstention barred a claim about expulsion from a private school: “Parents’ claims are premised on allegations that Prince of Peace failed to hire qualified staff and appropriately supervise its staff’s interactions with Students, including by failing to report suspected abuse of Students by its staff. Defense of these claims rests on Prince of Peace’s internal and religiously-informed policies and code of conduct. Judicial resolution of the claims would thus require impermissible intrusion in Prince of Peace’s management of these matters.” In re Prince of Peace Christian School, No. 05-20-00680-CV (Sept. 23, 2020) (mem. op.).

The Fifth Court granted mandamus relief to enforce the ecclesiastical abstention doctrine in In re First Christian Methodist Evangelistic Church: “[T]his case involves questions surrounding the termination of a church employee and allegations surrounding that termination. Like the claims asserted in those [prior] cases, the Senior Pastor’s claims do not present purely secular issues of contract law first and foremost because he was not terminated from a secular position. Moreover, the Senior Pastor was not terminated based on secular rules or procedures. Rather, the Church presented evidence that the Church Conference, which is comprised solely of members in good standing of the Church, voted to terminate the Senior Pastor’s employment ‘consistent with the internal policies and procedures of the Church.'” No. 05-18-01533-CV (Aug. 30, 2019) (mem. op.) (emphasis added).