Court says judicial review of church governance violates First Amendment protections
A Texas appeals court has ruled that the United Methodist Rio Texas Conference cannot sue dozens of churches that disaffiliated from the denomination without completing formal procedures, saying the case raises questions of church governance that secular courts have no authority to decide.
The ruling, issued October 29, 2025, by the Fourth Court of Appeals in San Antonio, upholds a lower court’s dismissal of the lawsuit filed by the Conference against more than 30 congregations across South Texas. At issue was whether the churches had to comply with Paragraph 2553 of the United Methodist Church’s Book of Discipline to retain church property after voting to leave the denomination.
The court found that interpreting the UMC’s disaffiliation rules would require entanglement in ecclesiastical matters, which the First Amendment forbids. The court emphasized that the Book of Discipline governs both doctrine and church structure, and civil courts cannot enforce or interpret its provisions.
The Conference argued that it was simply seeking enforcement of a contract-like provision and that courts could apply “neutral principles of law” to resolve the issue. But the court disagreed, noting that Paragraph 2553 was deeply tied to the UMC’s religious governance, and that determining whether churches had properly disaffiliated would necessarily require a court to interpret internal church policy and theology.
Judge Irene Rios, writing for the unanimous panel, stated that “judicial review and interpretation of the Discipline risks judicial entanglement with ecclesiastical matters.” The court held that even if contractual elements existed within the church documents, enforcing them would still cross constitutional boundaries.
The court also rejected the Conference’s claim that, even if jurisdiction was lacking, courts should still defer to the decisions of higher church authorities. Citing recent precedent from the Texas Supreme Court, the panel ruled that lack of jurisdiction means dismissal, not enforcement.
