Watson v. Jones (1871)
In 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) In 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) Held 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) Clarified 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) Established 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 such decisions.
Jones v. Wolf (1979) Expanded 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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