The principal issue in this case is essentially the same ownership question as those in 11-0332, Robert Masterson, et al. v. Diocese of Northwest Texas, et al., below: Whether in Texas a diocese seeking to leave the U.S. Episcopal Church or the larger Episcopal governing entity owns the church property in the diocese. The specific issue is whether ownership should be decided by "neutral principles"--using established trust and property law and taking account of deeds, the governing language employed by a local church and the larger denomination--or by "deference"--determining in a hierarchical church structure where church members place ultimate authority over property use. In this case the Fort Worth diocese, seeking to split from the larger national Episcopal church, appeals directly from summary judgment for the national church. The trial court used the deference approach to decide that the national church owned church property in the diocese.