In Colonial Presbyterian Church v. Heartland Presbytery, Case No. WD 74374, 2012 WL 2378232 (Mo.App. June 26, 2012), the Missouri Court of Appeals ruled that under the neutral principles of law approach, disputed church property was never conveyed in trust to the denomination and, thus, remained with the church. The court determined that the denomination’s constitution, which purported to convey the church property in trust, was not binding upon the church because the church never indicated an intention to create the trust in favor of the denomination by signing it. The denomination did not argue any basis for a constructive trust. Also, the constitution did not describe the property. Some of the church property lies in Kansas, but the court ruled that Missouri law applied, rather than the Kansas “rule of deference” standard, because both parties are Missouri entities and the most significant relationship test required it. Also, the court was skeptical that the Kansas Supreme Court would apply the rule of deference under the circumstances.