The Protestant Episcopal Church in the Diocese of New Jersey, the Trustees of Church Property of the Diocese of New…

Summary

The Supreme Court of New Jersey affirmed the Appellate Division’s judgment that the Protestant Episcopal Church and its diocese retain control over St. Stephen’s parish property. The Court applied the hierarchical (Watson) approach, holding that the parish is a subordinate entity of a hierarchical denomination and therefore must defer to the higher ecclesiastical authority. The decision also noted that even under a neutral‑principles analysis no trust in favor of the diocese was found, leading to the same result.