# United Methodist Rio Tex. Conference Bd. of Trustees v. Alice First Methodist Church Supreme Court of Texas, No. 25-1086 **United Methodist Rio Tex. Conference Bd. of Trustees v. Alice First Methodist Church, No. 25-1086, is before the Supreme Court of Texas. Key issue: Does the ecclesiastical-abstention doctrine bar a civil court from deciding a breach-of-contract suit that seeks the pension, insurance and administrative payments the United Methodist Book of Discipline requires of churches that disaffiliate, or can it be decided under neutral principles of law?** Practice areas: civil procedure ## Key issues - Does the ecclesiastical-abstention doctrine bar a civil court from deciding a breach-of-contract suit that seeks the pension, insurance and administrative payments the United Methodist Book of Discipline requires of churches that disaffiliate, or can it be decided under neutral principles of law? - Alternatively, may a civil court enforce the decision of a superior church body, the Conference, that the disaffiliating churches owe those payments? ## 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 (Brief on the Merits (Petitioner), PDF p. 16). 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 (Brief on the Merits (Petitioner), PDF pp. 18-19). 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 (Brief on the Merits (Petitioner), PDF pp. 19-20). 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" (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 (Brief on the Merits (Petitioner), PDF pp. 13, 20). The 285th District Court of Bexar County dismissed all claims for want of jurisdiction (Brief on the Merits (Petitioner), PDF pp. 13, 21). 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 (Brief on the Merits (Petitioner), PDF pp. 21-22). The Supreme Court granted review on June 12, 2026. ## Issues Presented - The Conference (Brief on the Merits (Petitioner), PDF p. 15): (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 (Response to Petition (Respondent), PDF p. 14): 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. ## 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 (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 (Brief on the Merits (Petitioner), PDF p. 22). 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 (Brief on the Merits (Petitioner), PDF p. 6). 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 (Reply to Response to Petition filed (Petitioner), PDF pp. 3, 7). **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 (Response to Petition (Respondent), PDF p. 19). 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 (Response to Petition (Respondent), PDF p. 34). **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 (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 (Petition for Review (Petitioner), PDF p. 23). 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 (Response to Petition (Respondent), PDF p. 19). ## Practice Area Tags civil-procedure ## Procedural Posture/Vehicle Petition for review from the San Antonio Court of Appeals; granted June 12, 2026. Oral argument: November 3, 2026. ## Amicus Involvement None noted --- Source: The SCOTX Report, https://scotxreport.com/cases/25-1086. AI-generated summary of the Court's opinion, orders and the parties' briefs, with pin cites to the page of each document; verify against the Court's own documents at search.txcourts.gov.