In Kedroff v. St. Nicholas Cathedral, the Supreme Court applied Gonzalez v. Roman Catholic Archbishop of Manila in the context of a state’s legislative action. This case involved a New York statute that recognized the administrative autonomy of Russian Orthodox Churches in North America from control by the Russian Orthodox Church in Moscow. The case arose when the American churches attempted to take possession of a cathedral occupied by the Russian church. The Court declared that the New York statute violated the First Amendment. The Court reaffirmed that whenever a case involves questions of religious discipline or faith, or ecclesiastical rule, custom, or law, the courts must accept such Church-rendered decisions as final, and as binding. Because there was nothing in the record that indicated the Russian Church abdicated power over the American Church, the Court concluded that it must abide by the ruling of the Russian Church that still maintained control over the American Church.
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