The SCOTX Report

The docket, decoded.
← Back to the June 12, 2026 issue
Petition For Review

United Methodist Rio Tex. Conference Bd. of Trustees v. Alice First Methodist Church

Case No. 25-1086

Key Issues

Factual History

The United Methodist Church is a connectional church organized into conferences, and the Rio Texas Conference (through its Board of Trustees) is the annual conference over local churches in its territory.1 The Conference says the Book of Discipline requires a local church that changes its relationship with the Church to contribute its unfunded pension liability, among other obligations, and that at least 68 churches in its territory complied and disaffiliated with the Church's blessing.2 The respondent local churches told the Conference they intended to disaffiliate but would not follow the Discipline's process or pay, except in a settlement, the required apportionments and unfunded pension liability, and some also dropped Conference-provided insurance without reimbursing its cost.3 The churches say the Conference's own petition roots its claims in the Discipline, the instrument setting forth the church's "laws, plan, polity, and process".4

Sources
  1. Brief on the Merits (Petitioner), PDF p. 16 ↩
  2. Brief on the Merits (Petitioner), PDF pp. 18-19 ↩
  3. Brief on the Merits (Petitioner), PDF pp. 19-20 ↩
  4. Response to Petition (Respondent), PDF p. 15 ↩

Procedural History

The Conference sued 28 local churches for breach and anticipatory breach of an express and implied contract to make the Discipline's required payments, seeking declaratory, contractual and injunctive relief, and the churches moved to dismiss for lack of jurisdiction without presenting evidence.1 The 285th District Court of Bexar County dismissed all claims for want of jurisdiction.2 The San Antonio Court of Appeals affirmed, holding that neutral principles could not be applied because the claims derive from a Discipline containing provisions on church doctrine and governance and because the full Discipline was not in the record, and it rejected the Conference's alternative argument that courts should defer to and enforce the Conference's decision.3 The Supreme Court granted review on June 12, 2026.

Petition for review from the San Antonio Court of Appeals; granted June 12, 2026. Oral argument: November 3, 2026.

Sources
  1. Brief on the Merits (Petitioner), PDF pp. 13, 20 ↩
  2. Brief on the Merits (Petitioner), PDF pp. 13, 21 ↩
  3. Brief on the Merits (Petitioner), PDF pp. 21-22 ↩

Issues Presented

  • The Conference:1 (1) whether courts have subject-matter jurisdiction because the suit seeks purely secular pension, insurance and administrative payments and can be decided under neutral principles without addressing ecclesiastical issues; and (2) alternatively, whether courts have jurisdiction to enforce the superior church body's decision that the local churches must make the payments.
  • The churches:2 whether review should be denied because the alleged obligations arise from the Book of Discipline, so adjudicating liability would require a civil court to construe and apply church law on disaffiliation and denominational authority.
Sources
  1. Brief on the Merits (Petitioner), PDF p. 15 ↩
  2. Response to Petition (Respondent), PDF p. 14 ↩

Standard(s) of Review

The Conference addresses the procedural standards for jurisdictional challenges based on the evidence, and notes that the churches presented no evidence with their motion to dismiss.1

Sources
  1. Brief on the Merits (Petitioner), PDF pp. 5, 20 ↩

Legal Arguments

Whether neutral principles allow the court to decide the contract claims.

The Conference (Petitioner): The suit is for breach of contract on purely secular monetary obligations and can be decided under neutral principles, as in Southern Methodist University v. South Central Jurisdictional Conference (Tex. 2025); the court of appeals erred by refusing neutral principles because the provisions derive from a document that also addresses religious matters, and by requiring the Conference to produce the entire Discipline.1 The mere presence of religious provisions in a document does not preclude enforcing its secular ones, construing a contract as a whole does not necessarily require intrusion into ecclesiastical matters, and the claims present no ecclesiastical issues.2 In reply, it says the Discipline's role as the contract's source is of no consequence, the absence of the whole Discipline from the record is of no consequence, and paragraph 1504.23 took effect at the close of the 2019 General Conference.3

The churches (Respondents): At the petition stage they argued the court of appeals did not reject neutral principles as a matter of law but held they could not resolve claims that the Conference itself rooted in the Discipline, with the governing church-law text not fully before the court, which is a routine application of settled law.4 The claims in substance ask a civil court to decide whether the churches had to comply with the Church's internal disaffiliation regime, an inquiry Texas law forbids.5

Whether a court may enforce the superior body's decision.

The Conference (Petitioner): In the alternative, because the Conference is a superior church body and has determined the churches owe the payments, courts have jurisdiction to enforce that decision, and the church-autonomy doctrine avoids any entanglement with religion.6

Sources
  1. Brief on the Merits (Petitioner), PDF p. 22 ↩
  2. Brief on the Merits (Petitioner), PDF p. 6 ↩
  3. Reply to Response to Petition filed (Petitioner), PDF pp. 3, 7 ↩
  4. Response to Petition (Respondent), PDF p. 19 ↩
  5. Response to Petition (Respondent), PDF p. 34 ↩
  6. Brief on the Merits (Petitioner), PDF pp. 15, 53 ↩

Stated Reasons the Court Should Take the Case

The Conference argued that the court of appeals committed jurisprudentially important error by refusing to apply neutral principles merely because the secular contract provisions derived from a document that also addresses religious issues.1 The churches argued review should be denied for three independent reasons, beginning with the point that the case is not the jurisprudential vehicle the Conference claims.2

Sources
  1. Petition for Review (Petitioner), PDF p. 23 ↩
  2. Response to Petition (Respondent), PDF p. 19 ↩

Amicus Involvement

None noted

The Docket

The following is current as of October 9, 2026.

DateEvent
02/12/2026Petition for Review (United Methodist Rio Texas Conference Board of Trustees)
04/10/2026Response to Petition (Alice First United Methodist Church, et al)
05/15/2026Reply to Response to Petition filed (United Methodist Rio Texas Conference Board of Trustees)
06/12/2026Case set for oral argument on November 3, 2026, at 9:00 a.m.
06/12/2026Brief on the Merits Ordered
08/03/2026Petitioner's Brief on the Merits
Full case docket for 25-1086search.txcourts.gov →