St. Mary of Egypt Orthodox Church v. Townsend

In St. Mary of Egypt Orthodox Church v. Townsend, 243 Ga. App. 188, 190 (532 SE2d 731) (2000), the local parish adopted uniform parish bylaws that were issued by the diocese and were "standard and obligatory for all parishes" in the diocese. Id. at 192. Those bylaws provided that no parish decision "with regard to the property shall be contrary to or in conflict with" the national church statutes, and that "all decisions and resolutions made by the parish in annual or special meetings shall be sent to the bishop for confirmation and that they do not become effective until receipt of such confirmation." Id. And, "most significantly, the articles of incorporation for St. Mary's explicitly affirm the submission of the parish corporation to the hierarchical authority of the OCA, stating: 'The corporation shall be subordinate and subject to The Diocese of the South of the Orthodox Church in America.'" Id.