40

Rush v. Yancey, 349 S.W.2d 337 (Ark. 1961) (“[W]here a minister of a congregational church is dismissed by action of the majority of the church, and thereafter usurps the pastoral duties, such majority are entitled to an injunction to restrain him, and to prevent him and his adherents from occupying and using the church without consent of the majority.”). See also Lily of the Valley Spiritual Church v. Sims, 523 N.E.2d 999 (Ill. App. 1988); Trinity Lutheran Evangelical Church v. May, 537 A.2d 537 (Pa. Common. 1988).