Church Autonomy Doctrine and Associational Standing Collide in Nonprofit Governance Dispute

In Jeremiah Counsel Corp. v. Young, the Texas Business Court's Eleventh Division confronted whether an incorporated association of church members has standing to challenge amendments eliminating congregational voting rights, and whether the First Amendment's church autonomy doctrine bars judicial review of those governance changes. Judge Dorfman's opinion navigates the boundary between constitutional religious autonomy and statutory obligations under the Texas Business Organizations Code for a 94,000-member nonprofit church corporation.