Central Coast Baptist Ass'n v. First Baptist Church of Las Lomas

Opinion

BAMATTRE-MANOUKIAN, Acting P. J. Central Coast Baptist Association (Central Coast) is a voluntary association of approximately 100 Southern Baptist churches in California’s central coast counties. First Baptist Church of Las Lomas (First Baptist) is a Southern Baptist church in Monterey County that is associated with Central Coast. Central Coast brought this action against First Baptist and against New Life Community Church of Prunedale (New Life) and New Life’s pastor, Hank Holley. Central Coast alleged that an attempted takeover of First Baptist by New Life, a nondenominational church, triggered a reversionary clause in article VII, section 3, of First Baptist’s constitution, which provided that the assets of First Baptist would pass to Central Coast either in the event of a “dissolution or winding up of the organization” or should First Baptist “cease to be a Southern Baptist Church.”

Following a bench trial, the trial court found in favor of Central Coast. The court found that First Baptist had “ceased to function as a Southern Baptist Church,” and that it had “de facto dissolved.” Based on these findings, the court ordered enforcement of the reversionary clause in First Baptist’s constitution, and ordered the transfer of First Baptist’s assets to Central Coast.

First Baptist and New Life appeal. They argue first that the court lacked jurisdiction to determine whether First Baptist had ceased to be a Southern Baptist church, because this required the court to decide matters involving religious doctrine and practice, thus violating fundamental precepts of separation of church and state contained in the First Amendment to the United States Constitution, as well as in our California Constitution. Appellants further contend that the trial court erred in finding that First Baptist “ceased to function as a Southern Baptist Church” rather than “cease[d] to be a Southern Baptist Church,” which was the language of the reversionary clause.

In addition, appellants contend that the court’s findings that First Baptist ceased to function as a Southern Baptist church and that it had “de facto [828]dissolved” were not supported by the evidence and that dissolution of a religious corporation such as First Baptist must comply with statutory formalities.

Appellants further contend that the court erred by failing to include in its order and judgment a requirement that all of First Baptist’s debts and liabilities be paid before transferring its assets to Central Coast, as provided in the reversionary clause. Finally, New Life contends that, since the two causes of action against it were dismissed prior to trial, the court’s judgment against it was in error.