In Conklin v. State of New York (284 A.D. 193, 130 N.Y.S.2d 618 [1954]) the plaintiffs, trustees of an unincorporated Methodist Church and the national Methodist Conference, sued the state for compensation after the church and its land, originally deeded directly to the church, were appropriated by the Palisades Interstate Park Commission. The Methodist Conference was successful in the trial court, but the church appealed, claiming that it was independent of the national organization and was the rightful owner of the property. The Court held that, because the property was given to the church in trust "for the promulgation of the tenets and doctrines of the Methodist Episcopal Church," and that the American Methodist Church was organized in a hierarchical fashion, that the church property was the possession of the national Methodist Church (Id. at 196-97, 130 N.Y.S.2d at 620).