Masterson v. Diocese of Northwest Texas
This Texas Supreme Court opinion addresses a church property dispute involving The Episcopal Church of the Good Shepherd. A majority of the local congregation voted to withdraw from The Episcopal Church of the United States (TEC) and the Episcopal Diocese of Northwest Texas due to doctrinal differences, renaming itself the Anglican Church of the Good Shepherd. The Diocese and loyal faction (Episcopal Leaders) sued to gain control of the property. The Court held that Texas courts must apply 'neutral principles of law' to resolve church property disputes, rather than deferring to hierarchical church decisions on property ownership. The previous summary judgment in favor of the Episcopal Leaders, based on the deference methodology, was reversed. The case was remanded for further proceedings consistent with the neutral principles approach, focusing on corporate bylaws, deeds, and state law regarding property and trusts.