African Methodist Episcopal Church, Inc. v. Ward

TJOFLAT, Circuit Judge:

This case arises out of a property dispute between the national African Methodist Episcopal Church, Inc. (the “AME Church”), and a Eatonton, Georgia, congregation currently known as Brown’s Chapel Community Church (“Brown’s Chapel”). For over one hundred years, beginning in the late nineteenth century, Brown’s Chapel was part of the AME Church. Then, in July 1994, the membership of Brown’s Chapel voted to disasso- date from the AME Church and become an independent, unaffiliated congregation. The congregation continued to meet in the building that it had used prior to…