Several of these rulings have involved the question of whether a trust relationship may serve to divest a local church of control of its property. See, e.g., Bishop and Diocese of Colorado v. Mote, Colo.Supr., 716 P.2d 85, 96, 103-09, cert. denied, 479 U.S. 826, 107 S.Ct. 102, 93 L.Ed.2d 52 (1986) (applying neutral principles of law approach in determination of trust for benefit of the general church); Babcock Memorial Presbyterian Church v. Presbytery of Baltimore of the United Presbyterian Church in the United States, Md.Ct.App., 296 Md. 573, 464 A.2d 1008, 1016-17 (1983), cert. denied, 465 U.S. 1027, 104 S.Ct. 1287, 79 L.Ed.2d 689 (1984) (using both a polity and neutral principles of law analysis); Fonken v. Community Church of Kamrar, Iowa Supr., 339 N.W.2d 810, 812, 819 (1983) (<HOLDING>). Other courts applying neutral principles of
holding that finding of implied trust in the general church was correct under both neutral principles of law and compulsory deference approaches recognizing 10th circuits finding of breach of trust holding that under california law a constructive trust may be sought only by the equitable owner of the trust res not by a creditor of the equitable owner holding that a church can have both a religious aspect and an economic one when the church operated a daycare center holding that the beneficiary of a trust was not the real party in interest regarding rights owned by the trust