Classis of Central California v. Miraloma Community Church
Filed September 15, 2009
Cite as 2009 SOS 5595

Church could not Amend Provisions when Bylaws say Otherwise

Being the oldest continuous evangelical Protestant denomination in United States, Reformed Church in America (RCA) was divided into 4 governmental units: the consistory, the classis, the regional synod and the General Synod.

The RCA as well as all its component entities and agencies, including local churches were administered by and organized in accordance with the Constitution of the RCA (RCA Constitution). RCA Constitution included chapters 1 and 2 of the Book of Church Order (Book of Order), namely “The Government” and “The Disciplinary and Judicial Procedures.”

According to the Book of Order, the consistory could not sell, encumber or transfer real property without the approval of the classis to which a church was a member. It also provided the procedure by which an affiliate can petition to withdraw from RCA in order to join with another denomination. Further, all real property becomes vested in appropriate classis whenever a church would be disbanded or dissolved.

Miraloma Community Church (Miraloma Church) originally incorporated as Grace Reformed announced its allegiance to the RCA.

Subsequently, it conducted itself as an RCA-affiliated church in accordance with hierarchical structure of the denomination, paying regular dues, providing annual statistical reports and submitting pastoral contracts and appointments to Classis of Central California (Classis) for its consent and approval. Moreover, it also enjoyed fruits of assistance, grants provided by RCA and its constituent bodies.

In accordance with the Book of Order, the Classis informed the Consistory of its intention to supersede the Consistory due to ‘long term decline in participation and membership’.

However, the members of the consistory refused to surrender power and attempted to leave the denomination. The members withdrew its account and deposited it in another account. It also took steps to terminate Miraloma Church’s affiliation with the Classis and RCA.

The Classis filed a suit. The trial court issued a temporary restraining order and preliminary injunction maintaining the status quo but permitting Miraloma Church to use its funds to pay the counsel. Eventually, the court granted summary adjudication on the declaratory cause of action and issued permanent injunction and permanent injunctive relief.

Consequently, Miraloma Church appealed.

The California Court of Appeal affirmed the judgment of the trial court. It ruled that the presbyterian organizational structure falls within general category of a hierarchical as opposed to a congregational church organization.

Hence, Miraloma Church could not amend its governing documents to terminate affiliation with the superior denominational entity, which was empowered to supersede its governing board.

This was because its bylaws confirmed that it was subject to and governed by the RCA's constitution and forbade amending or modifying this provision "in any manner" without written consent from the entity within the denominational hierarchy overseeing that church, based on neutral principles of law.