In Jones v. Wolf, the Supreme Court considered a property dispute between a local church and the general church to which the local church formerly belonged. The members of the local church brought a declaratory judgment action seeking an order establishing them as the owners of the church’s property. Applying neutral principles of property law, a state court decided in favor of the local church members. The general church challenged the state court’s decision on the grounds that the court’s resolution of an internal church matter violated the First Amendment. The Supreme Court held that a state is constitutionally entitled to adopt neutral principles of law governing the holding of a church’s property. According to the Court, the First Amendment does not mandate states to defer to religious authority in resolving church property disputes where no issue of doctrinal controversy is involved. Thus, so long as a court’s resolution of church property disputes is based solely on neutral principles of law and not an interpretation of church practice or dogma, a court may make the final determination as to property ownership. Because the lower court here did not articulate the exact basis of their opinion, the Court remanded the case so that the lower court could ensure the decision was actually based on neutral principles of law.
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