In Pure Presbyterian Church of Washington v. Grace of God Presbyterian Church, No. 171098, 2018 WL 3913151 (Va. Aug. 16, 2018), the Supreme Court of Virginia ruled that the trial court had subject matter jurisdiction to adjudicate a dispute between two Korean-speaking churches that had agreed to merge and entered an order enforcing the merger agreement. Pure Presbyterian filed for Chapter 11 bankruptcy. Learning of this, the Grace of God Presbyterian Church inquired about a merger. Pure Presbyterian was located in a more desirable location. The churches belonged to separate Korean Presbyterian denominations, but church officials agreed that they were doctrinally compatible. The Pure Presbyterian congregation approved the merger on Feb. 14, 2016, and the Grace Presbyterian congregation did likewise on Feb. 24, 2016. Joint services began on March 27, 2016. Grace Presbyterian listed and sold its property. Leaders drafted a "Merger Agreement" memorializing the merger and specifying pastoral roles. On Nov. 6, 2016, leaders of the unified church received an email stating that Pure Presbyterian wished to withdraw from the "proposed" merger. On Dec. 5, 2016, the pastor and a deacon discovered that they were locked out of the church building. In addition, Pure Presbyterian attempted to sell the property to a third party. At trial, Pure Presbyterian took the position that there was no merger contract and that, instead, the churches had agreed to a trial period so they could "get to know about the denomination and then the church." The jury returned a special verdict in favor of Grace Presbyterian, finding that the parties had reached a merger agreement. On appeal, Pure Presbyterian raised lack of subject matter jurisdiction for the first time. The Supreme Court of Virginia affirmed the judgment on the grounds that theological questions played no role in the jury's resolution of whether there was a merger agreement and whether it was breached.