Senior Law Clerk
First United Methodist Church of Hobe Sound, Florida, Inc., et al. v. Board of Trustees of the Florida Annual Conference of the United Methodist Church, Inc., et al. (Fla. 1st DCA Apr. 8, 2026)
A lot of cases look like straightforward real-estate disputes until you read the pleadings closely. The First District’s recent opinion in First United Methodist Church of Hobe Sound is a good example: the conflict centers on who gets to keep local church property after a group of congregations tries to leave the United Methodist Church. But the court treated it first and foremost as an intra-church governance dispute, and that framing drove the result.
The Basic Fight
A group of local Methodist churches wanted to disaffiliate from the UMC due to doctrinal conflict and, understandably, wanted to keep their real property when doing so.
The dispute wasn’t only “church versus church.” The parties first litigated internally within the denomination. The UMC’s highest adjudicatory body concluded that disaffiliation had to proceed under a specific provision of the UMC’s governing document (the Book of Discipline), and that decision required the local churches to pay a set amount to retain property upon disaffiliation.
After that internal ruling, the local churches filed suit in Florida state court seeking to invalidate aspects of the Discipline—essentially asking the court to undo what the UMC’s highest ecclesiastical court had already decided.
Why the trial court (and the First DCA) said “we can’t decide this”
The First DCA framed the issue bluntly: can a state court “wade into” an intra-church property dispute like this one?
The court explained that the U.S. Supreme Court has recognized two main approaches states may use for intra-church property disputes. One is the deference / ecclesiastical abstention approach (sometimes described as “hierarchical deference”), where civil courts accept the decisions of a hierarchical church’s highest tribunal on matters of internal governance.
The other is a neutral principles approach, where courts try to resolve disputes using secular legal principles (like deeds, corporate documents, or trust law) without deciding doctrinal questions.
Florida, the First DCA emphasized, follows the deference approach for hierarchical churches. As a result, the trial court concluded it could not adjudicate the claims because doing so would require the court to intrude into matters already resolved by the denomination’s highest internal court. The First DCA agreed and affirmed the dismissal.
A key point for practitioners: the court didn’t treat this as a situation where you can relabel the dispute as “trust law” and get jurisdiction. The churches’ amended complaint included counts attacking the Discipline’s trust clause under Florida trust and conveyance statutes, and other counts alleging fiduciary duty and seeking an accounting.
But the First DCA looked past the labels. The complaint itself, the court said, showed the case arose from an internal governance dispute—prompted by changes in the Discipline and the denomination’s internal adjudication of the proper pathway to disaffiliate.
The part that makes this one worth watching: certified question to the Florida Supreme Court
Even though it affirmed, the First DCA did something that signals the broader stakes: it certified a question of great public importance to the Florida Supreme Court.
That matters because these disputes are not isolated. They sit at the intersection of:
First Amendment constraints (courts can’t decide theology),
real property and trust principles (who holds title, who benefits from trust language), and
the reality that churches increasingly face disaffiliation disputes as denominations fracture.
The certified question tees up whether Florida’s approach should remain the same when plaintiffs bring state-law claims that, on their face, sound “secular,” but would effectively require a court to revisit an internal church adjudication.
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