In Carrollton Presbyterian Church v. Presbytery of South Louisiana of the Presbyterian Church, Case No. 2011 CA 0205, 2011 WL 4433571 (La. App. 1st Cir. Sept. 14, 2011), the court of appeals affirmed the trial court’s grant of summary judgment and permanent injunctive relief, prohibiting the Presbytery of South Louisiana from taking jurisdiction over Carollton Presbyterian Church’s session to prevent Carollton from selling its property. The court adopted a “neutral principles of law” approach to examining the Presbyterian Church (U.S.A.) Book of Order in the context of Louisiana trust law. The court ruled that the church invoked an exception within the Book of Order to the rule that all property belongs to the Presbytery and, even if it did not, Louisiana trust law would apply to vindicate church ownership of its own property. The court rejected the Presbytery’s argument that language in the temporary restraining order inhibited its free exercise of religion, because the temporary restraining order merged into and was superseded by the permanent injunction.