A Presbyterian church had a schism that led to a vote over whether to separate from the national church structure. The majority voted to separate itself and united with another denomination for their services. A dispute ensued over which faction had control over the church building itself- either the name of the trustees for the local church or the church organization. The higher church sided with the minority which it called the "true congregation". The lower courts ruled that the minority had control of the church by using the 'neutral principles of law'. In this case this criteria led the courts to settle the dispute on the language of the deeds, the terms of the church charter, state statutes, and the general church constitution.
The Supreme Court vacated the lower court's decision by a 5-4 vote. The case was ordered for re-argument before these lower courts.
| Majority Opinion: (Justice Blackmun) |
The general principle of "Neutral Principles of Law" can be used to resolve ownership disputes within a church. "The state has an obvious and legitimate interest in the peaceful resolution of property disputes, and in providing a civil forum where the ownership of church property can be determined conclusively." In this case, the state court did not properly articulate the grounds for its decision because this dispute was not between the church hierarchy and a local church but was between two factions of a local church. If the laws and regulations of the general church matter, deference to the local church's identity may be made by representatives of the church hierarchy. The NPoL can be used as long as the courts do not consider any religious doctrines. The lower courts can independently decide which criteria to use.
The Court asserted the interest in the state's settling of disputes regarding religious property. However, it failed to explicate which criteria should be used. Rather, it stated that one of these criterion cannot be religious doctrine.
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