First Evangelical Methodist Church v. Clinton

In First Evangelical Methodist Church v. Clinton, 257 Ga. 459, 460 (1), (2) (360 SE2d 584) (1987), the Georgia Supreme Court considered the language of two deeds as dispositive in determining the ownership of church property, reaching different results as to each deed. The first deed conveyed property to trustees "in connection with the affiliations aforesaid" with a connectional church. The court held that the deed vested title in the connectional church, and when the local church severed its relationship with that church it "forfeited its right of use and possession." Id. at 460 (1). But as to a second deed which contained no trust language and no restriction regarding its use, "the application of neutral property principles must yield a contrary result," and the court held the conveyance was to the local church and the parcel remained its property. Id. at 460 (2).