Certificate of Formation Controls Over Conflicting Bylaws in Nonprofit Governance Dispute

In Sri Shirdi Sai Baba Temple of Austin v. Lam, Division 3 granted summary judgment for defendants, holding that a nonprofit corporation's certificate of formation stating it "will have no members" and vesting management in the board controls over 2025 bylaws purporting to convert the entity to a member-managed corporation. The court rejected any jurisdictional bar from the church-autonomy doctrine, finding the dispute presented a non-ecclesiastical issue of corporate governance decidable by neutral application of Texas corporate law.