## Facts

- Vineville Presbyterian Church in Macon, Georgia, was organized in 1904 and incorporated in 1939; its property was acquired with funds contributed by local members.
- The church affiliated with the Presbyterian Church in the United States (PCUS), a denomination with a generally hierarchical structure, through the Augusta-Macon Presbytery.
- A congregational vote produced a split: 164 members voted to withdraw from the PCUS and join another denomination, while 94 opposed withdrawal.
- The withdrawing majority retained possession of the local church property.
- The Presbytery appointed a commission that determined the minority faction was the “true congregation” within the PCUS and removed the majority’s authority derived from the PCUS.
- The minority faction filed a class action in Georgia state court seeking declaratory and injunctive relief awarding it exclusive possession and use of the property as the continuing PCUS congregation.

## Issues

1. Whether the First and Fourteenth Amendments permit a state to resolve church property disputes by applying “neutral principles of law” rather than deferring to determinations of religious authorities in a hierarchical church.
2. Whether Georgia’s neutral-principles approach was constitutionally applied where the local congregation itself was divided and the Presbytery commission had recognized the minority faction as the “true congregation.”

## Decision

- The Supreme Court held that a state may constitutionally adopt a “neutral principles of law” method for adjudicating church property disputes.
- The Court rejected any constitutional rule requiring compulsory deference to hierarchical church authorities in all such disputes.
- The Court vacated the Georgia judgment and remanded because the record did not clearly show that the state courts’ resolution rested on sufficiently neutral, secular grounds given the complication of a split congregation.

## Legal Principles

- The First Amendment allows civil courts to resolve church property disputes using neutral, secular legal rules drawn from deeds, statutes, corporate charters, and church constitutions, so long as courts avoid deciding questions of religious doctrine or practice.
- States are not constitutionally required to defer to hierarchical church authorities’ decisions on property ownership, though deference remains a permissible approach if applied without doctrinal adjudication.
- Civil courts may examine religious documents for property-related provisions (including trust language) only in secular terms and may not treat such review as an authoritative resolution of internal church doctrine.
- When a congregation divides, a state’s application of neutral principles must be clearly grounded in secular property and corporate law rules and must not depend on deciding which faction is religiously legitimate.

## Conclusion

The Court approved neutral-principles adjudication of church property disputes as consistent with the First Amendment, but required remand because the state-court reasoning did not clearly demonstrate a neutral, secular basis for awarding the property to the withdrawing majority in an intra-congregational split.


Jones v. Wolf, 443 U.S. 595 (1979)