The Ohio Court of Appeals has affirmed a lower court's decision in a property dispute involving the Independent Church of God and Saints of Christ and its former pastor, Lenton Stevens. The court ruled that Stevens failed to demonstrate excusable neglect in his appeal, which centered on his removal as pastor and subsequent possession of church property.
This case, titled Independent Church of God & Saints of Christ v. Stevens, No. 25AP-520, began when the Independent Church filed a lawsuit against Stevens in May 2023. The church alleged that Stevens was removed as pastor in July 2019 but continued to occupy the church’s property, preventing the congregation from accessing it. The church sought damages and an order to regain possession of the property located on Hildreth Avenue in Columbus, Ohio.
Stevens responded by filing a motion to dismiss the complaint, arguing that the court lacked jurisdiction under the ecclesiastical abstention doctrine. This doctrine typically prevents courts from intervening in matters related to religious doctrine and church governance. However, the trial court denied Stevens' motion, stating that it had jurisdiction over secular issues, such as property disputes.
The case then proceeded to a magistrate for a bench trial in November 2024. After the Independent Church presented its case, Stevens moved for an involuntary dismissal, which the magistrate granted. The magistrate concluded that while the church had established legal title to the property, it failed to prove that Stevens wrongfully retained possession or caused damages. Consequently, the magistrate dismissed the church's complaint with prejudice.
Stevens filed objections to the magistrate's decision, arguing that the church did not establish its legal claim to the property. However, he also failed to file a required trial transcript within the specified timeframe. After the trial court reviewed his objections, it sustained one and overruled the rest, ultimately adopting the magistrate's decision and dismissing the church's claims.
In May 2025, Stevens filed a motion for relief from judgment under Civil Rule 60(B), claiming his attorney's failure to file the trial transcript constituted excusable neglect. The trial court denied this motion, stating that Stevens had not shown any excusable neglect. Stevens then appealed this ruling.
The Ohio Court of Appeals, led by Judge Dingus, reviewed Stevens' appeal and found that he could only challenge the denial of his Civ.R. 60(B) motion. The court noted that he could not raise issues regarding the underlying judgment because he had missed the deadline to appeal that decision. The court stated, "A party may not use Civ.R. 60(B) to circumvent or extend the time requirements for filing an appeal."
Ultimately, the court ruled that Stevens did not demonstrate excusable neglect. The court pointed out that his attorney's failure to file the transcript was a result of mere neglect rather than an oversight that warranted relief. The court stated, "The inquiry into whether inaction constitutes excusable or inexcusable neglect must take into consideration all the individual facts and circumstances in each case."
As a result of this ruling, the Ohio Court of Appeals affirmed the lower court's judgment, effectively upholding the dismissal of the Independent Church's claims against Stevens.
This decision has implications for similar disputes involving religious organizations and property rights, as it reinforces the importance of timely appeals and the necessity for parties to adhere to procedural requirements. The ruling may serve as a precedent for future cases where the jurisdiction of courts over ecclesiastical matters is questioned.
Looking ahead, it remains unclear whether Stevens will seek further legal recourse, as the court's decision appears to close the door on this particular dispute. Details were not available in the court filing regarding any potential related cases or further appeals.