In Brown v. Clark, 102 Tex. 323, 116 S.W. 360, 363 (Tex. 1909), there was a dispute between rival factions of a local Presbyterian church. The court carefully avoided any ecclesiastical issues, including whether the local church possessed the authority to enter into a union with the Presbyterian denominational church. Id. at 364. The court then considered "perhaps the only question in the case of which this court has jurisdiction," i.e., how the union with the denominational church affected the possession and control of the local church property. Id. The court examined the deed, which was in the name of the local church, but recognizing that the local church "was but a member of and under the control of the larger and more important Christian organization," held that only those members of the local church loyal to the denominational church were entitled to use and possession of the property. Id. at 365.