Berkley Center

Presbyterian Church v. Mary Elizabeth Blue Hull Memorial Presbyterian Church involved a property dispute between a general church and several local churches that were once members of the general church. The local churches decided to withdraw from the general church because they believed that certain actions and pronouncements of the general church were inconsistent with the organization’s doctrine and practice. The local churches filed suit to enjoin the general church from trespassing on their property. The state court considering the matter decided for the local churches on the grounds that their separation was based on a fundamental departure by the general church from the organization’s religious tenets. The Supreme Court reversed the state court’s finding on the grounds that it was based on an interpretation of the organization’s religious beliefs, which violated the First Amendment. The Court reiterated that it is essential for religious organizations to have a right to establish tribunals for the decision of internal matters, and that those decisions be final and generally not subject to external review. The Court held that the First Amendment prohibited courts from resolving controversies over religious doctrine and practice; if civil courts undertook to resolve such controversies, they might inhibit the free development of religious doctrine. Thus, because the state court based its decision on an interpretation of the organization’s doctrine, the Court reversed the decision of the lower court.