Bethel AME Church of Newberry v. Domingo
Cases that cite this one
4 later published cases cite this decision.
- First United Methodist Church of Hobe Sound, Florida, Inc. v. the Board of Trustees of the Florida Annual Conference of the United Methodist Church, Inc. (Fla. Dist. Ct. App. 2026)
- Sts. Peter and Paul Russian Orthodox Greek Catholic Church of Miami, Florida, Inc. v. Diocese of the South, Orthodox Church in America (Fla. Dist. Ct. App. 2026)
- DISTRICT ADVISORY BOARD OF THE SOUTHERN FLORIDA DISTRICT, CHURCH OF NAZARENE, INC., etc. and BRIAN WILSON v. CENTRO DE ALABANZA OASIS WEST PALM BEACH, INC. and IGLESIA DEL NAZARENO BELEN, INC. (Fla. Dist. Ct. App. 2022)
- New Jerusalem Church of God, Inc. v. Sneads Community Church, Inc. (Fla. Dist. Ct. App. 2013)
This list shows which later cases cite this one. It does not say how they treated it, and no review of that has been done. Not a substitute for Shepard’s or KeyCite — verify before relying.
Opinion of the Court
In this church schism case, the trial court erroneously entered summary judgment for appellees/defendants, the withdrawing members of Bethel AME Church of Newberry, concluding that they were the rightful owners of the church property. The principle of church structure which governs church property disputes, as articulated in the controlling case of Mills v. Baldwin, 362 So.2d 2 (Fla. 1978), vacated on other grounds, 443 U.S. 914, 99 S.Ct. 3105, 61 L.Ed.2d 878 (1979), reinstated on remand, 377 So.2d 971 (Fla. 1979), cert. denied, 446 U.S. 983, 100 S.Ct. 2964, 64 L.Ed.2d 839 (1980), requires that church property remain with the parent church where, as here, the church is hierarchical in structure. Given the trial court’s finding that the AME Church is hierarchical, judgment should have been entered in favor of appellants/plaintiffs as representatives of the original church.
Accordingly, we reverse the appealed order and direct entry of judgment in favor of the appellants.
Case-law data current through December 31, 2025. Source: CourtListener bulk data.