Background
The Eritrean Orthodox Tweahdo Church’s Holy Synod appointed Abune Sinoda as Bishop of the United States and Canada in 2005. Sinoda later formed the petitioner, a Maryland religious corporation that acquired a Hyattsville property in 2011 and used it as a parsonage. Sinoda lived there with the corporation’s permission, without a written lease and without paying rent.
In 2016, the Synod defrocked Sinoda and removed him as bishop. The corporation repeatedly directed him to vacate the property, but he refused, maintaining that the Synod was illegitimate and that he remained the rightful bishop and corporate leader. The District Court dismissed the corporation’s wrongful-detainer action under the ecclesiastical abstention doctrine, reasoning that deciding possession would require resolving the religious leadership dispute. The Circuit Court for Prince George’s County affirmed.
The Court’s Holding
The Supreme Court of Maryland held that ecclesiastical abstention did not apply because the possession dispute could be resolved through neutral principles of Maryland property law. The court did not need to decide whether the Synod was legitimate or whether Sinoda’s removal complied with church doctrine. Nothing in the church documents or other evidence gave the incumbent bishop a legal possessory interest in the parsonage.
The undisputed evidence established that the corporation held title to the property and that Sinoda occupied it as a licensee, not a tenant. There was no lease, no rent, and no evidence that the corporation granted him an exclusive tenancy. Because a property owner may revoke a license to occupy its property, and the corporation had undisputedly revoked Sinoda’s permission, he was holding the property without a right of possession. The corporation therefore was entitled to judgment on its wrongful-detainer claim.
Key Takeaways
- Ecclesiastical abstention bars adjudication only when resolving a claim necessarily requires a court to decide questions of religious doctrine, faith, or governance.
- A court must apply neutral legal principles when it can resolve a church-related property dispute without determining which religious faction or leader is legitimate.
- Occupancy of a church-owned parsonage without a lease, rent payments, or an exclusive right of possession may constitute a revocable license rather than a tenancy.
Why It Matters
The decision clarifies that the presence of an internal religious leadership controversy does not automatically prevent Maryland courts from adjudicating related property rights. The controlling question is whether civil ownership and possession can be determined without resolving the underlying ecclesiastical dispute.
For religious organizations and clergy, the ruling also underscores the importance of documents expressly defining any property rights associated with religious office. Absent such provisions, church-owned housing may remain subject to ordinary state property law regardless of a dispute over who rightfully holds the ecclesiastical position.