concurring in part and dissenting in part.
I fully agree with Division 1 of the per curiam opinion that this appeal comes within our jurisdiction over equity cases and that we therefore must resolve the merits thereof. However, I strongly disagree with Division 2 because, in the absence of any showing or ruling of estoppel, the relatively recent provision of the “Discipline” of the AME Church on which the majority relies cannot provide the basis for the requisite application of the “neutral principles of law” method to a title obtained by the local church decades prior to adoption of that provision. Furthermore, this analysis would make the enumerations addressed in Divisions 3 and 4 moot.
Where, as here, no funds are donated by the general church to *331purchase and develop the local church property,
[n]o trust in favor of the general church may be implied under the general trust statutes ([cits.]).... However, [OCGA § 14-5-46] recognizes and validates deeds conveying land for church purposes according to the limitations set out in the deed and for use “according to the mode of church government or rules of discipline .. . .”
Carnes v. Smith, 236 Ga. 30, 38 (1) (222 SE2d 322) (1976).
In this case, the only deed is a security deed by trustees of Williams Chapel which does not expressly state that the property is held in trust for the AME Church. The affidavits of title, which contain no trust language, do not constitute deeds or other documents of conveyance. See OCGA § 44-2-20. Furthermore, the allegedly long relationship between the local church and the connectional organization, “without more, is insufficient to create an implied trust.” Coles v. Wilburn, 241 Ga. 322, 323 (245 SE2d 273) (1978).
However, the constitutionally authorized “neutral-principles method, at least as it has evolved in Georgia, requires a civil court to examine certain religious documents, such as a church constitution, for language of trust in favor of the general church.” Jones v. Wolf, 443 U. S. 595, 604 (III) (99 SC 3020, 61 LE2d 775) (1979). This Court “has looked consistently to the requirements of the church discipline in hierarchical denominations to avoid offending the prohibitions of the First Amendment.” Crumbley v. Solomon, 243 Ga. 343, 345 (254 SE2d 330) (1979). See also Holiness Baptist Assn. v. Barber, 274 Ga. 357, 358 (552 SE2d 90) (2001).
The majority relies on the following portion of the “Discipline” of the AME Church: “The title(s) to all real, personal and mixed property held ... by the local churches, shall be held IN TRUST for the [AME] Church, Inc. ...” However, the record contains no evidence whatsoever regarding when this provision was adopted. Thus, Appellees, as plaintiffs in this quiet title action, have wholly failed to show that such provision was already in effect when the local church obtained title by gift. See Simmons v. Community Renewal and Redemption, 286 Ga. 6, 8 (2) (685 SE2d 75) (2009). To the contrary, examination of precedent involving the AME Church clearly shows that the trust provision at issue was not contained in the 1972 version or earlier versions of the quadrenially-updated Discipline. Mt. Olive African Methodist Episcopal Church of Fruitland v. Bd. of Incorporators of the African Methodist Episcopal Church, 703 A2d 194, 196 (I) (Md. 1997). The trial court found that Appellants’ interest in the property began over 70 years ago. Indeed, the undisputed evidence shows that Williams Chapel built a church *332on the property, and therefore its title was perfected, decades before 1972. Accordingly, the local church obtained title long before adoption of the trust provision on which the majority relies. “Although the neutral-principles approach to the resolution of property disputes includes consideration of any church constitutions under Jones, supra, it is appropriate to first consider ... the church constitution in place at the time” when the local church obtained title. Arkansas Presbytery of the Cumberland Presbyterian Church v. Hudson, 40 SW3d 301, 309 (IV) (Ark. 2001). It is well-settled that a party has a right to rely on the law in effect at the time he obtains title. See Williams v. Brown, 267 Ga. 215, 216 (1) (476 SE2d 753) (1996); Arkansas Presbytery of the Cumberland Presbyterian Church v. Hudson, supra at 310 (IV). There has been neither any showing nor ruling that the local church here is estopped from continued reliance on the Discipline which was in effect when it obtained title. Compare Crumbley v. Solomon, supra (where the local church participated in making a new disciplinary rule which implied a trust for the benefit of the general church). Therefore, exclusive control over the church property in this case is properly vested in the local church. Arkansas Presbytery of the Cumberland Presbyterian Church v. Hudson, supra.
As explained in a very recent law review article, favoritism of national churches in the manner set forth by the majority has First Amendment implications which are staggering. The majority’s determination that a hierarchical church can unilaterally impress a trust in its favor of local congregational property depends on dicta from Jones v. Wolf, supra at 606 (III), as quoted in footnote 4 of the per curiam opinion, but effectively ignores
the important qualification in the Jones v. Wolf dicta that the obligation of civil courts is to honor “the result indicated by the parties.” [Cit.] In simpler language, civil courts must give effect to bilateral agreements, and a unilateral declaration of trust by the putative beneficiary is not a bilateral agreement. . . . [The majority’s] decision to grant hierarchical churches a unique authority to impress a trust upon property they do not own merely by declaring that the church is the trust beneficiary of that property is [a] ... startling cession of governmental power to a religious organization. This is . . . the . . . extraordinary power to seize property by divesting others of their beneficial interests in the property. . . . Donors of property to local churches are not necessarily members of the hierarchical church. Such donors have no assurance that their intent to transfer property in trust for the exclusive benefit of the local *333church, and not the hierarchical church, will be honored. All the general church would need to do is alter its own internal governing instruments to nullify the explicit intentions of donors.
Calvin Massey, Church Schisms, Church Property, and Civil Authority, 84 St. John’s L. Rev. 23, 46-49 (III) (2010). Accordingly, I believe that we should follow the persuasive authority of Arkansas Presbytery of the Cumberland Presbyterian Church v. Hudson, supra at 309-310 (IV).
Moreover, even if the majority were justified in relying upon a trust provision added to the Discipline long after the local church obtained title by gift, that provision is not an existential proposition, and instead imposes a “requirement” on local churches “that property held by ‘the local churches’ shall be held ‘IN TRUST’ for the [AME] Church, Inc.” African Methodist Episcopal Church v. Stewart, 28 S3d 1044, 1046 (La. App. 2009). The immediately succeeding provision begins with the transition “However” and addresses the situation where, as here, the local church has not taken steps which meet that requirement. This second provision specifically deals with “the absence of an IN TRUST clause as indicated herein, in deeds, and documents of conveyance previously executed.” This language refers back to the trust requirement of the first provision, as it is the only other provision which even mentions holding property in trust, and treats that provision as contemplating the execution of some deed or document of conveyance containing an “in trust” clause. See Coles v. Wilburn, supra at 324. Under the terms of the second provision, the absence of such an express “in trust” clause in some appropriate document “shall not exclude a local church from or relieve it of its Connectional character and responsibilities” nor “excuse or absolve a local congregation” from its responsibilities and accountability to the AME Church, provided that certain conditions are met, including “conveyance of said property to the trustees of a local church or agency to the AME Church, Inc.” The language of this particular condition
is at best ambiguous. Even so, nothing in [any deed, or in the affidavits of title for that matter,] can be interpreted to convey the property “to the A.M.E. Church, Inc.” . . . Conveyance is to [or by] the local church, but not “to the A.M.E. Church, Inc.” .. . Applying the neutral principles of law that are evoked by our examination of the documents and evidence in purely secular terms . . ., [I] conclude that [Appellees have] failed to establish compliance with a necessary provision of the Discipline. [The] A.M.E.’s Discipline, *334therefore, does not contain regulations that effectively vest control of the property at issue in it under the facts of this case.
African Methodist Episcopal Church v. Stewart, supra at 1047-1048. There simply are “no ‘neutral principles of law’ entitling the [A.JM.E. Church to the local church . . . property.” Coles v. Wilburn, supra at 324 (where the Discipline contemplated the creation of express trusts by deed to the general church, and no deed to the general church existed).
Because of the majority’s reliance on an inapplicable provision of the Discipline and its strained interpretation thereof, I respectfully concur in part and dissent in part to the affirmance of the trial court’s judgment.
I am authorized to state that Chief Justice Hunstein joins in this opinion.