If you drove past the iconic stone spires of Highland Park Methodist Church on the corner of Mockingbird Lane and Hillcrest Avenue near Southern Methodist University this week, you wouldn’t notice anything out of the ordinary. The quiet sanctuary stands as a testament to nearly a century of faith, fellowship, and service. But inside the Sunday school classrooms, leadership committee meetings, and coffee hour chats, the mood is heavy.
Earlier this month, the congregation received news that left many members heartbroken and bewildered: the Horizon Texas Conference of the United Methodist Church has officially filed a lawsuit against Highland Park Methodist Church.
What Is the Disagreement Actually About?
According to UM News coverage and statements by Bishop Rubén Saénz Jr., the conference views its legal petition as a matter of covenantal accountability. The dispute centers on governance updates passed by our Church Council in 2022. That is, Highland Park removed the word “United” from its corporate legal name, shifted authority over pastoral appointments and board selections exclusively to the Church Council, circumventing traditional denominational processes, and modified provisions regarding member voting on certain key institutional decisions.
The conference argues these edits attempt to sever the connectional tie that binds every United Methodist congregation to the wider body. They contend that legal intervention is necessary to “protect the congregation” and restore the church’s governing documents into compliance with the Book of Discipline.
From the perspective of the local pastors and lay leaders of a church that had the highest membership in the Conference and gave the most “apportionments” each year to the Conference, the lawsuit felt like a “complete shock.” Senior Pastor Rev. Matt Tuggle publicly expressed his grief and confusion, saying leadership felt “blindsided” after engaging in good-faith dialogue with conference representatives. Pastor Tuggle and former senior minister Rev. Paul Rasmussen have consistently reaffirmed that Highland Park remains dedicated to its United Methodist heritage and identity.
In their view, unlike the 10,000 or so churches that formally disaffiliated in recent years, Highland Park has never voted or sought to leave the United Methodist Church. The governance updates were designed to provide stability and local operational flexibility using secular Texas property precedents, such as Episcopal Diocese of Fort Worth v. Episcopal Church, rather than breaking denominational ties. Following the filing, our Church Council passed a resolution declaring it no longer recognizes the ecclesiastical authority of the bishop or conference to direct our local clergy or operations, citing a duty to shield our pastors and ministry from punitive administrative actions.
The legal fight has moved beyond quiet negotiations into a civil court challenge where judges will determine how neutral law applies to church bylaws.
As the case moves through Dallas County courts, it serves as a critical test case for how non-profit law and neutral property principles intersect with denominational authority in Texas. The neutral principles of law doctrine is the primary legal framework Texas courts use to resolve property and governance disputes involving religious organizations. It allows secular courts to decide property ownership, corporate control, and contractual obligations without violating the First Amendment of the U.S. Constitution.
Ecclesiastical Deference vs. Neutral Principles
To understand how Texas courts apply this doctrine, it helps to compare it to the traditional alternative:
| Framework | How It Works | Key Characteristics |
| Ecclesiastical Deference | Civil courts blindly defer to the decision of the highest governing body or bishop of a hierarchical church. | The national denomination or regional conference automatically wins property disputes upon claiming authority. |
| Neutral Principles of Law | Civil courts apply standard state property, trust, and non-profit corporate laws to the dispute. | Courts evaluate deeds, corporate charters, bylaws, and state statutes just as they would for a secular non-profit. |
Texas is firmly committed to neutral principles in a pair of landmark 2013 Texas Supreme Court rulings, which culminated in the decisive 2020 decision.
In Masterson v. Diocese of Northwest Texas (2013), the Texas Supreme Court formally held that Texas courts must use neutral principles rather than ecclesiastical deference. The court ruled that when a local church corporation validly amends its bylaws under Texas corporate law to withdraw from a national church, civil courts must recognize those secular corporate actions—even if church canon law forbids them.
In Episcopal Diocese of Fort Worth v. Episcopal Church (2020), following a split over theological issues, a majority faction of the Episcopal Diocese of Fort Worth voted to disaffiliate from The Episcopal Church (TEC). TEC appointed new loyalist leaders and sued for control of $100 million in church property, arguing that under denominational canon law (specifically the “Dennis Canon”), all local property was held in an irrevocable trust for the national church. Applying neutral principles, the Texas Supreme Court ruled unanimously for the withdrawing local diocese.
Thus, when a Texas judge applies strict neutral principles to a church property dispute, they review four primary source documents:
- Property Deeds: Who holds formal legal title to the real estate on county land records?
- Articles of Incorporation & Bylaws: What do the local non-profit’s governing documents say about voting rights, board powers, and amendment procedures?
- State Statutes: Does the action comply with the Texas Business Organizations Code and Texas Trust Code?
- Denominational Rulebooks: Do national church canons (like the UMC Book of Discipline) form an enforceable contract or express trust under Texas civil law?
Application of “Neutral Principles” to Disputes
In disputes between regional conferences and local mega-churches, neutral principles give local congregations strong leverage if their deeds and corporate bylaws favor local control. However, if the local church previously executed clear contracts, express trust agreements, or charter language binding itself irrevocably to the regional conference, Texas courts will enforce those secular constraints.
The enforceability of the UMC Trust Clause depends entirely on state geography. In deference or hybrid states, the national denomination holds a clear advantage, as internal church canons are treated as decisive contracts. In strict neutral-principles states like Texas, secular corporate registration and recorded property deeds control the outcome, giving autonomous local church boards a strong statutory path to retain local assets.
What happens next?
Complex civil litigation in a Dallas County District Court follows a structured timeline dictated by the Texas Rules of Civil Procedure (TRCP) and local court rules. A governance and property lawsuit like the instant case typically unfolds across five main phases:
Phase 1: Pleadings & Jurisdiction Thresholds: Months 1–3.
- Petition & Service: The plaintiff (Horizon Texas Conference) files its original petition seeking declaratory judgment. Service of process is formally served on HPUMC’s registered agent.
- Answer & Special Exceptions: HPUMC files its answer (typically within 20+ days of service). Counsel may file Special Exceptions challenging the sufficiency of the pleadings or move to dismiss based on the Ecclesiastical Abstention Doctrine, arguing the court lacks subject-matter jurisdiction to hear church disputes.
Phase 2: Preliminary Injunctions & Temporary Orders: Months 1–4 (If accelerated).
- Preserving the Status Quo: If the Conference fears HPUMC might execute further bylaw changes, transfer assets, or alter pastoral leadership unilaterally, it may seek a Temporary Injunction.
- Evidentiary Hearing: The judge holds a mini-trial to determine whether to freeze corporate governance actions while the lawsuit is pending.
Phase 3: Discovery & Document Production: Months 4–12.
- Written Discovery: Both sides exchange requests for production, interrogatories, and admissions. Key targets include 2022 board meeting minutes, emails between local leadership, and corporate filings.
- Depositions: Attorneys depose key figures—including Senior Pastor Rev. Matt Tuggle, local Church Council members, and Conference leadership.
Phase 4: Summary Judgment Motions: Months 10–14.
- Dispositive Motions: Because this case hinges on interpreting written documents (the Book of Discipline, Texas non-profit corporate filings, and land deeds) under “neutral principles”, both sides will likely file Motions for Summary Judgment.
- Court Ruling: If the judge agrees there are no genuine issues of material fact, the lawsuit can be decided entirely at this stage without a full jury trial.
Phase 5: Court-Ordered Mediation, Trial, & Appeals: Months 12–24+.
- Mandatory Mediation: Dallas County judges routinely order parties to court-annexed mediation before trial to push for a negotiated settlement.
- Bench or Jury Trial: If unresolved, a trial takes place before the district judge.
- Appeals: Given the significant legal stakes, the losing party will almost certainly appeal to the Fifth Court of Appeals in Dallas and ultimately petition the Texas Supreme Court.
Feel free to reach out to Daniel Dalton or one of the team members of Dalton & Tomich PLC to discuss how this case impacts your denominational relationship decision-making.
