A congregation divides. One faction keeps the keys, the other keeps the mailing list, and the denomination writes a letter announcing that the sanctuary has always been held in trust for the national church. Everyone assumes the fight will be about theology. It will not be. In Minnesota it will be about a deed, a set of articles of incorporation, and whether a particular sentence in a denominational constitution satisfies the ordinary requirements of an express trust under state law. The theology is the one thing a Minnesota judge is forbidden to touch.
That is the whole architecture of this area, and it produces a result most clients find backwards: the document the general church leads with — the trust clause in its own constitution — is frequently the weakest piece of paper on the table, while the local congregation’s own articles of incorporation, which nobody has read since the day they were filed, decide the case.
Minnesota follows neutral principles, and has since December 1982
The First Amendment does not pick the method. As Jones v. Wolf put it, a state “may adopt any one of various approaches for settling church property disputes so long as it involves no consideration of doctrinal matters, whether the ritual and liturgy of worship or the tenets of faith.” 443 U.S. 595, 602 (1979) (quotation omitted). In practice the field has narrowed to two: compulsory deference to whatever the highest tribunal of a hierarchical church decides, or neutral principles of secular property and trust law applied to the documents. Minnesota chose the second, and said so in as many words.
In Piletich v. Deretich, 328 N.W.2d 696 (Minn. 1982), a schism in the Serbian Eastern Orthodox Church of St. Sava in South St. Paul put the question squarely to the Minnesota Supreme Court. Chief Justice Amdahl wrote:
Finding present Minnesota law to be harmonious with the neutral principles of law approach, we now formally adopt this approach to resolution of church property and membership disputes.
328 N.W.2d at 701. That is the sentence to cite. It was handed down on December 30, 1982, with rehearing denied on February 14, 1983, and no Minnesota decision since has moved off it.
Piletich also told practitioners exactly what to gather. A neutral-principles analysis, the court explained, “relies upon the language of deeds, the terms of local church charters, state statutes governing the holding of church property, provisions in the constitution of the general church concerning the ownership and control of church property, explicit trust provisions, and general rules of property law.” Id. at 700. Six categories, and every one of them is a document.
The court then stated Minnesota’s default rule. Reading its own prior decisions together, it described “a presumptive rule of majority representation, defeasible upon a showing that the identity of the local church is to be determined by some other means under written rules of church government, with an expressed willingness by the court to enforce the contractual agreements of the parties.” Id. at 702. The majority of the congregation wins — unless a written rule the congregation actually adopted says someone else decides.
The method came straight out of Jones, where the Supreme Court held that “a State is constitutionally entitled to adopt neutral principles of law as a means of adjudicating a church property dispute,” 443 U.S. at 604, and praised the method because it “relies exclusively on objective, well-established concepts of trust and property law familiar to lawyers and judges,” id. at 603. Jones also approved the majority-representation presumption, observing that “the majority faction generally can be identified without resolving any question of religious doctrine or polity.” Id. at 607.
What a Minnesota court may not decide at all
Neutral principles is a method, not a license. A separate body of federal constitutional law — the ecclesiastical abstention doctrine, also called the church autonomy doctrine — removes certain questions from civil courts entirely, and it removes them no matter how the plaintiff labels the claim.
The Minnesota Supreme Court synthesized the governing United States Supreme Court decisions in Pfeil v. St. Matthews Evangelical Lutheran Church, 877 N.W.2d 528 (Minn. 2016). Three rules came out of it. “First, a court cannot overturn the decisions of governing ecclesiastical bodies with respect to purely ecclesiastical concerns, such as internal church governance or church discipline.” Id. at 534. “Second, a court may not entertain cases that require the court to resolve doctrinal conflicts or interpret church doctrine.” Id. Third, a court may resolve a dispute involving a religious organization only if it can rely exclusively on neutral principles of law, does not disturb a governing ecclesiastical body’s ruling on doctrine, and “the adjudication does not interfere with an internal church decision that affects the faith and mission of the church itself.” Id.; see MoChridhe v. Academy of Holy Angels, 29 N.W.3d 753 (Minn. App. Dec. 1, 2025) (No. A25-0559) (restating the three rules), review granted.
The federal law underneath those rules is emphatic. In Presbyterian Church in the United States v. Mary Elizabeth Blue Hull Memorial Presbyterian Church, 393 U.S. 440 (1969), the Court held Georgia’s departure-from-doctrine implied trust unconstitutional and reversed, because the First Amendment “commands civil courts to decide church property disputes without resolving underlying controversies over religious doctrine.” Id. at 449. And in Serbian Eastern Orthodox Diocese v. Milivojevich, 426 U.S. 696 (1976), the Court held that where a dispute cannot be resolved without extensive inquiry into religious law and polity, “the First and Fourteenth Amendments mandate that civil courts shall not disturb the decisions of the highest ecclesiastical tribunal within a church of hierarchical polity, but must accept such decisions as binding on them, in their application to the religious issues of doctrine or polity before them.” Id. at 709. Milivojevich went further and rejected any “arbitrariness” review of a church tribunal’s decision, reasoning that secular notions of fundamental fairness “are therefore hardly relevant to such matters of ecclesiastical cognizance.” Id. at 715.
So the excluded territory is: doctrine, internal church discipline, and who serves as clergy. A Minnesota court will not decide which faction is theologically faithful, will not review an excommunication, and will not second-guess a bishop. It will, however, decide who the members of a church corporation are when that question turns on the corporation’s own written rules rather than on doctrine. Piletich adopted neutral principles for “church property and membership disputes,” 328 N.W.2d at 701, and quoted its own earlier decision for the proposition that “[t]hat right to a share in the government of a corporation is a civil right, which the law will protect, and the courts will therefore determine who are the members of the corporation.” Id. at 702 (quoting Blauert v. Schupmann, 241 Minn. 428, 435, 63 N.W.2d 578, 583 (1954)).
Two Minnesota decisions show how much ground that covers.
In Patterson v. Bethel Baptist Church, 389 N.W.2d 729 (Minn. App. 1986), ousted members sued over their right to use the church building and name after the congregation declared an “organic division.” The court of appeals affirmed summary judgment for the church and said the thing plaintiffs’ counsel least wants to hear: “The fact that a claimed property right may be involved does not automatically remove a doctrinal dispute once it has arisen, from the Piletich bar against civil courts resolving doctrinal disputes.” Id. at 733. Pleading a property claim does not convert a doctrinal fight into a justiciable one.
In Friends to Restore St. Mary’s, LLC v. Church of Saint Mary, Melrose, 934 N.W.2d 130 (Minn. App. 2019), a limited liability company formed by current and former parishioners of a fire-damaged Melrose church — a building dedicated in 1899 and listed on the National Register of Historic Places in 1993 — sued under the Minnesota Environmental Rights Act to stop its demolition. That is about as secular a statute as exists. It did not matter. The bishop had decided to build anew rather than restore, and MERA’s affirmative defense turns on whether there is a “feasible and prudent alternative,” which the court could not try without disturbing the bishop’s ruling. The claim was barred. The court added, in a footnote, that it need not evaluate whether neutral principles could resolve the dispute if applying those principles would itself violate the ecclesiastical abstention doctrine.
One procedural point from Pfeil matters more than it looks. The court held “that the doctrine is not a jurisdictional bar to adjudication,” and expressly left open whether it operates as an affirmative defense on the merits or as a form of abstention. 877 N.W.2d at 535. Practically: raise it, plead it, brief it, and do not assume the district court will find it on its own or that it can be raised for the first time on appeal as a defect in subject-matter jurisdiction.
Does a denominational trust clause bind a congregation that never adopted it?
This is the question that decides real cases, and Minnesota’s answer is no — not standing alone.
Jones v. Wolf itself told general churches how to win these disputes, and the instruction is not subtle:
At any time before the dispute erupts, the parties can ensure, if they so desire, that the faction loyal to the hierarchical church will retain the church property. They can modify the deeds or the corporate charter to include a right of reversion or trust in favor of the general church. Alternatively, the constitution of the general church can be made to recite an express trust in favor of the denominational church. The burden involved in taking such steps will be minimal. And the civil courts will be bound to give effect to the result indicated by the parties, provided it is embodied in some legally cognizable form.
443 U.S. at 606. Read the last clause twice. “Some legally cognizable form” means the state’s own law of trusts and conveyances decides whether the words worked.
Minnesota’s law of express trusts is not forgiving. The essentials, the supreme court held in Bond v. Commissioner of Revenue, 691 N.W.2d 831 (Minn. 2005), are “(1) a designated trustee with enforceable duties; (2) a designated beneficiary vested with enforceable rights; and (3) a definite trust res in which the trustee has legal title and the beneficiary has the beneficial interest.” Id. at 837. And the intent has to come from the right person: “A trust is created only if the settlor demonstrates, by external expression, the intent to create a trust.” Id. The settlor is the party whose property is going into the trust — here, the congregation that owns the building.
That requirement is what a denominational trust clause typically fails. In Presbytery of the Twin Cities Area v. Eden Prairie Presbyterian Church, Inc., No. A16-0945 (Minn. App. Apr. 24, 2017), a presbytery of the Presbyterian Church (U.S.A.) sued a departing congregation, relying on the Book of Order’s declaration that all property held by or for a congregation “is held in trust nevertheless for the use and benefit of” the denomination. The court of appeals rejected the argument in one clean stroke: the Book of Order language “did not create an express trust as it is devoid of any language demonstrating the specific intent of EPPC to create a trust under Minnesota law. At most, the language contained in the Book of Order is indicative of the intent of the beneficiary, PCUSA, not the settlor, EPPC.” A denomination cannot declare itself the beneficiary of property it does not own.
That opinion is nonprecedential. Under Minn. R. Civ. App. P. 136.01, subd. 1(c), nonprecedential opinions “are not binding authority except as law of the case, res judicata or collateral estoppel, but nonprecedential opinions may be cited as persuasive authority.” Cite it for what it is — the only Minnesota appellate decision squarely on the trust clause, decided under settled Minnesota trust law — and do not overstate it.
The rest of the Eden Prairie analysis is where most of the money is. When the congregation amended its own articles of incorporation in 1999 to recite that legal title to all its property is held “in trust, nevertheless, for the use and benefit” of the denomination, that did create an express trust: it named a trustee, a beneficiary, and a res, and it was the settlor speaking. But the same articles reserved the power to amend them by majority vote at a properly noticed meeting. An unrestricted power to amend carries the power to revoke, and the congregation exercised it in 2010 by a vote of 160 to 1. The trust was validly revoked and the property stayed local.
Two Minnesota rules drive that outcome, and both cut in the general church’s favor if it drafts carefully:
- Minn. Stat. § 501C.0602(a): “Unless the terms of a trust expressly provide that the trust is revocable, the settlor may not revoke or amend the trust.” A congregation that adopts trust language and says nothing about amendment has, by statutory default, made it irrevocable.
- Minn. Stat. § 513.04, the statute of frauds for interests in land, provides that no “trust or power over or concerning lands” may be created “unless by act or operation of law, or by deed or conveyance in writing, subscribed by the parties creating, granting, assigning, surrendering, or declaring the same, or by their lawful agent thereunto authorized by writing.” A denominational constitution is not subscribed by the congregation, and the denomination is not the congregation’s lawful agent authorized in writing. The Eden Prairie court flagged that argument in a footnote and declined to reach it because the trust failed on other grounds. It is still there, and I would raise it.
So the honest advice to a departing congregation is: your exposure is measured by what your own recorded and filed documents say, not by what the denomination’s constitution says. And the honest advice to a denomination is: get it into the deed or into the congregation’s articles, and close the amendment door.
Which corporation statute governs your church is not obvious
Minnesota has two separate corporate regimes for religious bodies, and lawyers guess wrong on this constantly.
Chapter 315 — “Religious Societies” — is the old regime. It lets worshipers elect between three and 15 trustees “to take charge of its property and temporal affairs,” Minn. Stat. § 315.01, subd. 2, and gives those trustees power to hold, purchase, mortgage, sell, convey, lease, and improve the property, § 315.04. Section 315.05 draws a line that surprises people: “The trustees may not fix the salary of a minister; it must be fixed by a majority of the society entitled to vote at the election of trustees.”
Chapter 315’s sale provision is the one that stops closings. Under § 315.12, before the trustees may sell, convey, or encumber real estate they “must first be authorized by resolution of the society adopted by a two-thirds vote of the members present and voting at a meeting called for that purpose,” with notice given “for at least four successive Sabbaths immediately before it on which the society statedly meets for public worship.” The section then supplies its own proof machinery: “[p]roof of nonexistence, notice, meeting, and the adoption of resolution may be made by the affidavit of a trustee or member of the society cognizant of them,” that affidavit “must be recorded with the county recorder where the certificate of incorporation was recorded,” and the affidavit and record “are presumptive evidence of the facts they contain.” The same section adds that “[n]o religious corporation shall sell, transfer, or otherwise dispose of its real estate except as provided by the denominational rules and certificates of association of the society as it appears of record in the office of the county recorder of the county.” Denominational rules matter under chapter 315 — but the statute ties them to what is of record.
That machinery is not decorative. In Chapman v. Salem Lutheran Church, 301 Minn. 486, 221 N.W.2d 129 (1974) (per curiam), a church’s failure to furnish “a copy of the notice and proceedings authorizing sale” killed a house closing: the title insurer refused to issue a policy, and the supreme court held the church “could not execute a valid deed to plaintiffs until the requirements of § 315.12 were met” and that “the seller could not convey a marketable title to buyers until the sale was authorized in accordance with statute.” Id. at 487. The buyers got their earnest money back. Chapman construed the pre-1976 wording, which required a two-thirds vote “of the members” rather than of the members present and voting, but the authorization requirement it enforced is the one still in the statute. What Chapman does not decide is what becomes of a deed already delivered and recorded without that authorization, and I have found no Minnesota decision that does. So the answer for a title examiner or a buyer is the record itself: adopt the resolution and record the affidavit before closing, because Minnesota gives you no case law on how that fight comes out afterward.
Chapter 317A, the Minnesota Nonprofit Corporation Act, is the modern regime, and it does not automatically apply:
This chapter does not apply to a religious corporation authorized by chapter 315 unless it is formed under this chapter or elects to be governed by this chapter as provided in section 317A.021.
Minn. Stat. § 317A.051, subd. 2. Chapter 317A’s general sweep-in provision, § 317A.021, subd. 7(a), likewise carves out chapter 315 corporations that never came under the older chapter 317. A religious corporation may also elect to be governed by only §§ 317A.601 to 317A.671 — the chapter’s merger, consolidation, and transfer-of-assets provisions — without electing the whole chapter, in which case it records with the county recorder rather than the secretary of state. § 317A.051, subd. 2.
Before you write a demand letter, find out which chapter the entity lives under. It changes the vote required to convey, where the documents are recorded, and who has standing to sue.
The split is usually won on fiduciary duty, not theology
The most instructive Minnesota church-property decision handed down after Piletich never reached the trust question at all.
In Shepherd of the Valley Lutheran Church of Hastings v. Hope Lutheran Church of Hastings, 626 N.W.2d 436 (Minn. App. 2001), a Missouri Synod congregation split over a pastor. Its constitution actually contained a division clause: property followed doctrinal adherence if the split was doctrinal, and “[i]f division takes place for non-doctrinal reasons, the property shall remain with the majority of the communicant members.” Id. at 440. A majority of those present at the annual meeting voted to separate on non-doctrinal grounds and to transfer the real estate and personal property to a newly formed church for no consideration.
The court of appeals never had to construe the clause. The congregation’s vice president had organized the breakaway while still in office, held secret meetings, had articles, a constitution, bylaws, and a warranty deed prepared without telling the other officers, and admitted on cross-examination that he withheld material information from the president. That was a breach of fiduciary duty. It also cost him the immunity Minn. Stat. § 317A.257, subd. 1, gives a person who serves a tax-exempt organization without compensation, because that immunity reaches only an act that “did not constitute willful or reckless misconduct.” And the district court’s equitable remedy — returning the church property to the original corporation, plus $7,782.99 in damages — was affirmed. Id. at 441–44. The court noted the settled rule that legal title obtained through a breach of fiduciary relationship gives rise to a constructive trust in favor of the party equitably entitled to the property. Id. at 444.
The lesson has nothing to do with religion. An officer of a Minnesota nonprofit corporation must act “in good faith, in a manner the officer reasonably believes to be in the best interests of the corporation, and with the care an ordinarily prudent person in a like position would exercise under similar circumstances,” Minn. Stat. § 317A.361, subd. 1, and a church officer who quietly engineers a property transfer to the faction he intends to join hands the other side a cleaner case than any First Amendment argument would have produced.
Two more chapter 317A details worth knowing. Section 317A.361, subd. 2, provides that “[a]n officer is not considered to be a trustee with respect to the corporation or with respect to property held or administered by the corporation” — which disposes of the loose claim that church officers hold the building “in trust” simply by virtue of office. And the equitable-remedy provision for a violation of the chapter, § 317A.467, requires that the action be brought “by at least 50 members with voting rights or ten percent of the members with voting rights, whichever is less, or by the attorney general.” In a small congregation, ten percent is a handful of people. In a large one, the fifty-member ceiling controls. Count before you file.
Dissolution and merger: the statutes supply their own answers
If the split ends in a wind-up rather than a fight, different provisions govern, and they can change the answer.
Under chapter 315, a religious society “under the control or supervision of a superior body” that “ceases to exist or to maintain its organization” has its real and personal property vest in the next higher governing or supervising corporate body of the same denomination. Minn. Stat. § 315.37. That is a statutory reversion to the denomination — but it is triggered by extinction, not by schism, and it does not happen by letterhead. Section 315.38 requires an application to the district court of the county where the society was located, a hearing, and three weeks’ published and posted notice, after which the court directs the transfer through a trustee it appoints. Two or more incorporated churches may consolidate under § 315.34, and where each has formed a property-holding corporation, those corporations may merge under § 315.365, with legal title vesting in the survivor.
Under chapter 317A, the order of distribution on dissolution is fixed by § 317A.735. Two subdivisions decide church cases. Subdivision 2 provides that assets “may not be diverted from the uses and purposes for which the assets have been received and held, or from the uses and purposes expressed or intended by the original donor.” Subdivision 3 is the sleeper:
Where the articles or bylaws of the dissolving corporation, or the rules or canons of another organization by which the dissolving corporation is bound, provide for a particular distribution of the assets of the dissolving corporation, the assets must be distributed accordingly.
The legislature has supplied a neutral principle that gives denominational canons real force — conditioned entirely on the congregation being bound by them, which puts you right back into the documents.
Then the attorney general. A corporation holding assets for a charitable purpose, or exempt under section 501(c)(3), must notify the attorney general of an intent to dissolve, merge, consolidate, convert, or transfer all or substantially all of its assets, and the notice must itemize, among nine required items, the assets, the restricted assets and their restrictions, the debts, the anticipated expenses including attorney fees, and the persons who will receive the assets. Minn. Stat. § 317A.811, subd. 1. It may not transfer assets until 45 days after that notice unless the attorney general waives the wait, § 317A.811, subd. 2, and the attorney general may extend the period by one additional 30 days, subd. 3. There is a real exception: subdivision 6 removes the notice and waiting requirements for a merger with, consolidation into, conversion into, or transfer of assets to another 501(c)(3), requiring only that a copy of the certificate be sent. Two churches merging with each other usually land in the exception. A church dissolving does not.
The four documents I want before I say a word
I do not give a view on a church property dispute until I have read four things, in this order.
- Every deed in the chain, pulled from the county recorder or registrar of titles — not the copy in the church safe. Whose name is on the conveyance, and does it contain a reversionary clause or trust language? If the parcel is registered land, the certificate of title controls what encumbrances survive, and that is a different analysis.
- The articles of incorporation as filed, with every amendment, in filing order. This is where trust clauses actually live or die, and where you learn whether the power to amend was reserved, restricted, or never addressed.
- The bylaws in force at the relevant time, plus the minutes and meeting notices for the votes that adopted or amended them. Under § 315.12 the notice and vote requirements are a precondition to the trustees’ power to convey, and Chapman is what happens at the closing table when they were not met.
- The denominational constitution, canons, or book of order — in the version in force on the date that matters, not the version on the website today. In Eden Prairie the presbytery’s addendum contained a mission-of-the-church clause that appeared for the first time in the current edition and was absent from the versions that governed the dispute. Editions matter.
If those four documents point in the same direction, the case is short. If they conflict, the fight is a real one, and the vehicle is usually a declaratory judgment action construing the instruments under Minn. Stat. § 555.02, often paired with a quiet title count. That is a property case with a First Amendment perimeter around it — which is exactly how Minnesota law wants it framed.
Madgett Law, LLC
I handle disputes over real property, nonprofit corporate governance, and the documents that decide both — deeds, articles, bylaws, and the trust and reversion language buried in them. Congregational splits sit at the intersection of all three, and they reward the side that gathered its records first. If your congregation, denomination, or nonprofit board is facing a property dispute, or wants its governing documents fixed before one starts, call 612-470-6529 or send us a message.
Related reading: Minnesota nonprofit corporations under chapter 317A · quiet title actions under § 559.01 · the Minnesota Declaratory Judgment Act · Torrens registered land · corporate dissolution and winding up
Sources: Piletich v. Deretich, 328 N.W.2d 696 (Minn. 1982) (at 699, First Amendment deference to hierarchical tribunals on doctrine or polity; at 700, the six categories of documents a neutral-principles analysis examines; at 701, formal adoption of the neutral-principles approach for church property and membership disputes; at 702, the presumptive rule of majority representation, and the quotation from Blauert v. Schupmann, 241 Minn. 428, 435, 63 N.W.2d 578, 583 (1954), that the courts will determine who are the members of a church corporation; at 703, result). Jones v. Wolf, 443 U.S. 595 (1979) (at 603, advantages of neutral principles; at 604, holding that a State may adopt neutral principles, and duty to defer where interpretation would require resolving a religious controversy; at 606, how a general church may secure the property and the “legally cognizable form” requirement; at 607, majority-representation presumption). Presbyterian Church in the U.S. v. Mary Elizabeth Blue Hull Mem’l Presbyterian Church, 393 U.S. 440, 449 (1969) (command to decide church property disputes without resolving doctrinal controversies). Serbian E. Orthodox Diocese v. Milivojevich, 426 U.S. 696 (1976) (at 709, mandate to accept the decisions of the highest ecclesiastical tribunal of a hierarchical church; at 715, rejection of an “arbitrariness” exception; at 724–25, church tribunals’ decisions binding on civil courts). Pfeil v. St. Matthews Evangelical Lutheran Church, 877 N.W.2d 528 (Minn. 2016) (at 532, roots of the doctrine in church property and schism cases; at 534, the three rules; at 535, doctrine is not a jurisdictional bar). MoChridhe v. Academy of Holy Angels, 29 N.W.3d 753 (Minn. App. Dec. 1, 2025) (No. A25-0559), review granted (restating the Pfeil rules; third factor dispositive). Friends to Restore St. Mary’s, LLC v. Church of Saint Mary, Melrose, 934 N.W.2d 130 (Minn. App. 2019) (ecclesiastical abstention bars a MERA claim whose affirmative defense cannot be tried without disturbing the bishop’s decision). Patterson v. Bethel Baptist Church, 389 N.W.2d 729 (Minn. App. 1986) (at 732, right to share in corporate government is a civil right; at 733, a claimed property right does not remove a doctrinal dispute from the Piletich bar, and enforcement of a constitution committing the property question to a denominational board). Shepherd of the Valley Lutheran Church of Hastings v. Hope Lutheran Church of Hastings, 626 N.W.2d 436 (Minn. App. 2001) (at 440, the congregation’s division clause; at 441, neutral principles; at 441–43, breach of fiduciary duty and loss of § 317A.257 immunity; at 443–44, equitable return of the property, $7,782.99 in damages, and constructive trust). Presbytery of the Twin Cities Area v. Eden Prairie Presbyterian Church, Inc., No. A16-0945 (Minn. App. Apr. 24, 2017) (nonprecedential) (Book of Order trust clause expresses the beneficiary’s intent, not the settlor’s; congregation’s own articles created an express trust; reserved power to amend carried the power to revoke; statute-of-frauds argument not reached). Minn. R. Civ. App. P. 136.01, subd. 1(c) (effect of nonprecedential opinions), verified at revisor.mn.gov/court_rules/ap/subtype/rcap/id/136/. Bond v. Commissioner of Revenue, 691 N.W.2d 831, 837 (Minn. 2005) (essentials of an express trust; settlor’s external expression of intent). Minn. Stat. § 315.01, subd. 2 (election of trustees to take charge of property and temporal affairs); § 315.04 (trustees’ powers over property); § 315.05 (management powers; minister’s salary fixed by the society); § 315.12 (two-thirds vote of members present and voting, four successive Sabbaths’ notice, the recorded affidavit as presumptive evidence of notice, meeting and resolution, and denominational rules of record); Chapman v. Salem Lutheran Church, 301 Minn. 486, 487, 221 N.W.2d 129 (1974) (per curiam) (a religious corporation could not execute a valid deed or convey marketable title until § 315.12’s authorization requirements were met; construing the pre-1976 wording); § 315.34 (consolidation); § 315.365 (merger of property corporations); § 315.37 (property of a defunct subordinate society vests in the next higher body); § 315.38 (district court application, hearing, three weeks’ notice, court-appointed trustee); § 317A.021, subd. 7(a) (chapter 315 carve-out); § 317A.051, subd. 2 (chapter 317A does not apply to a chapter 315 religious corporation absent formation or election); § 317A.257, subd. 1 (immunity for uncompensated service, lost for willful or reckless misconduct); § 317A.361, subds. 1–2 (officer standard of conduct; officer not considered a trustee); § 317A.467 (equitable remedies; 50 members or ten percent, whichever is less, or the attorney general); § 317A.735, subds. 2–3 (no diversion from original purposes; distribution per articles, bylaws, or binding canons); § 317A.811, subds. 1–3, 6 (attorney general notice, 45-day waiting period, 30-day extension, 501(c)(3) exception); § 501C.0102(a) (chapter 501C applies to express trusts, charitable or noncharitable); § 501C.0602(a) (a trust is irrevocable unless its terms expressly provide otherwise); § 513.04 (no trust concerning lands except by writing subscribed by the party creating it); § 555.02 (declaratory construction of deeds and written instruments), all verified at revisor.mn.gov. This article is general legal information about Minnesota law. It is not legal advice, it does not create an attorney–client relationship, and no particular outcome is promised or implied.