In Jones v. Wolf, 443 U.S. 595 (1979), the Supreme Court ruled that, under the religion clauses of the First Amendment, a state could resolve disputes over church property between two groups by applying neutral principles of law rather than relying on compulsory deference to religious authority. However, the Court remanded the case to the lower court to ensure that the state had applied such neutral principles, rather than resolving it by considerations of religious doctrine and polity.

Faced with a schism in the Vineville Presbyterian Church of Macon, Georgia, between a majority who had split from the church to join the Presbyterian Church of America and a minority who wanted to stay with the Presbyterian Church in the United States, the state court attempted to resolve the issue of who owned church property by applying “neutral principles of law,” which the U.S. Supreme Court had commended in Presbyterian Church in the United States v. Mary Elizabeth Blue Hull Memorial Presbyterian Church (1969).

Finding nothing in the deeds, state statutes, or the Book of Church Order regarding any trust to the general church, Georgia courts awarded the property to the faction in the congregation with the majority of members. Because the U.S. Supreme Court could not tell from the record whether Georgia had constitutionally applied the neutral-principles analysis or whether it was influenced in part by church doctrine, it remanded the case for further consideration. Specifically, it could not ascertain why the state court had deferred to majority rule in the case or whether, or how, the state would allow other evidence to overcome this rule.

Justice Harry A. Blackmun’s majority opinion stressed that the First Amendment mandated that civil courts have a limited role in resolving church property disputes. As long as they did not examine doctrinal matters, states could apply neutral principles of law rather than adopt compulsory deference to the denomination’s highest authority, which had been decided in some cases of churches that were hierarchically arranged.

In a dissenting opinion joined by Chief Justice William H. Rehnquist and Justices Potter Stewart and Byron R. White, Lewis F. Powell Jr. argued that the Court’s analysis was “more likely to invite intrusion into church polity” than to prevent it. Powell thought it was more relevant to examine the church government; in the case at hand, the church was part of a hierarchical structure and the church’s most authoritative body had declared in favor of the minority of the congregation. Watson v. Jones (1871), thus dictated that its decision should prevail.

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