Teleforum

The United States Supreme Court first acknowledged what would become the church autonomy doctrine, also known as the ecclesiastical abstention doctrine, in the 1871 case of Watson v. Jones, 80 U.S. 679 (1871). That case involved a schism in a Presbyterian church in Louisville, Kentucky, over the issue of slavery. The Court fashioned a principle that civil courts should not decide issues regarding faith, doctrine, and membership. Later, in Kedroff v. Saint Nicholas Cathedral, 344 U.S. 94 (1952), the Court cemented the rule of deference to ecclesiastical bodies in internal church disputes, grounding the rule in the First Amendment and applying it to states through the Fourteenth Amendment. However, a competing rule emerged in certain circumstances in a 5-4 decision in Jones v. Wolf, 443 U.S. 595 (1979). In Jones, a divided Court held that civil courts may also use “neutral principles” of law to resolve church schisms involving property disputes. Today, courts wrestle with the dilemma of applying def