Significant Supreme Court Rulings
Watson v. Jones (1871)
a dispute within a congregation over control of its property, held that federal
courts should not become involved in determining which faction is adhering more
closely to traditional church doctrine. Instead, the high court found that federal courts
should determine whether the congregation has a hierarchical structure. The
court also decided that if the congregation does belong to a hierarchical
denomination, courts should defer to the denomination’s decision about which
faction is entitled to the property.
Bouldin v. Alexander (1872)
disputes involving religious congregations that do not have a hierarchical
leadership structure, ruled that civil courts have the power to decide whether
a faction that claims authority in the congregation has the legal right to
exercise such authority. However, courts may do so only if such a ruling would
not require the court to interpret religious doctrine.
Gonzalez v. Archbishop of Manila (1929)
that civil courts do not have the authority to determine who is qualified to be
a priest. The court ruled that such determinations are within the exclusive
jurisdiction of religious organizations.
Presbyterian Church in the United States v. Mary Elizabeth Blue Hull Memorial Presbyterian Church (1969)
that the U.S. Constitution is the source of the rule (first articulated in Watson v. Jones) prohibiting civil courts
from deciding religious questions when resolving disputes within religious
organizations. This meant that the prohibition applies not only to federal
courts but also to state courts.
Serbian Eastern Orthodox Diocese v. Milivojevich (1976)
that state courts do not have jurisdiction to determine whether a hierarchical
church body acted “arbitrarily” in removing a bishop from office. Citing Watson and other decisions, the court held
that the First Amendment precludes civil courts from reviewing the substance of
Jones v. Wolf (1979)
the options open to courts in resolving church property disputes. As in the
past, courts may still decide such a case by deferring to a denominational
hierarchy or a congregational majority. Alternatively, however, a court is free
to decide these cases using “neutral principles of law.” This means a court may
examine any materials that it would examine in cases involving a similar
dispute in a secular organization, such as property deeds, articles of
incorporation or any other legal documents, as long as the court does not need
to interpret religious doctrine in assessing these sources.
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