Background
Central Presbyterian Church in Huntington, Suffolk County has owned property at 240 Main Street since 1864 and 1888. In 1980, the Presbytery of Long Island—the regional governing body of the Presbyterian Church (U.S.A.) (PCUSA)—voted to adopt an amendment to the UPCUSA constitution providing that all property held by local congregations shall be held in trust for the use and benefit of the denomination. Central’s pastor and two Elder Commissioners attended that 1980 meeting.
In 2013, Central declared its intention to separate from PCUSA, and in 2016, Central voted by near-unanimous vote to leave the denomination and join another. Central and the Presbytery could not agree on the disposition of the 240 Main Street property. In September 2019, the Presbytery sued for a declaratory judgment that the property is held in trust for the denomination. Central cross-moved to quiet title in itself. The Supreme Court, Suffolk County (Luft, J.) denied Central’s cross-motion and, searching the record, awarded summary judgment to the Presbytery declaring the property held in trust. Central appealed.
The Court’s Holding
The Appellate Division, Second Department affirmed. New York applies the “neutral principles of law” approach to church property disputes, as established by the U.S. Supreme Court in Jones v. Wolf (443 US 595). Under this framework, courts apply ordinary principles of property law, contract, and trust—without relying on religious doctrine—to determine the parties’ intent regarding property ownership. Courts look to: the language of the deeds, the local church charter, applicable state statutes, and the provisions of the denomination’s constitution regarding property ownership and control.
Here, the PCUSA Constitution expressly provides that all property held by or for a congregation “is held in trust . . . for the use and benefit of the [PCUSA]” and that such property shall be administered by the presbytery when a congregation ceases to use it as a PCUSA congregation. Under New York’s Religious Corporations Law § 69(3), trustees of an incorporated PCUSA congregation are required to administer its property in accordance with the PCUSA Constitution. Central’s trustees were thus legally bound to hold the property in trust for the denomination, and the 1980 constitutional amendment—adopted with notice to Central’s representatives—established the trust interest. Central’s departure from the denomination did not change this: the trust continued even as Central left the PCUSA.
Key Takeaways
- Under New York’s neutral principles of law approach, courts enforce a denominational trust in church property where the denomination’s constitution expressly establishes a trust, the state’s Religious Corporations Law requires local trustees to comply with that constitution, and the local church’s representatives had notice of the trust provision.
- A congregation’s decision to leave a hierarchical denomination does not extinguish a previously established denominational property trust; property held in trust for the denomination at the time of departure continues to belong to the denomination after the departure.
- Notice matters: when a local church’s officers attend the denominational meeting at which a trust amendment is adopted, the local church cannot later claim it was unaware of the trust obligation.
- Religious Corporations Law § 69(3) is a significant lever in PCUSA property disputes: it requires incorporated PCUSA congregations to administer their property under the PCUSA Constitution, giving civil courts an independent statutory basis—separate from the church constitution—to enforce the trust.
Why It Matters
Presbytery of Long Island v. Central Presbyterian Church is an important property dispute for faith communities in New York navigating denominational splits and realignments. The decision confirms that PCUSA’s “trust clause”—the constitutional provision establishing that all congregational property is held in trust for the denomination—is enforceable under New York’s neutral principles approach, particularly when the local church’s leadership had notice of the trust provision and when New York’s Religious Corporations Law independently compels adherence to the denomination’s constitution.
For faith communities and their legal counsel, the case signals that congregations wishing to retain their real property when leaving a hierarchical denomination must act before any constitutional trust provision is adopted—or negotiate a specific property exception—not after the fact. Once the trust is established and the local church’s representatives had notice of it, departure from the denomination does not undo the trust. Congregations in the midst of denominational transitions should seek legal counsel early regarding the effect of denominational constitutions and New York’s Religious Corporations Law on property rights.