## Facts

- Two local Presbyterian congregations in Savannah, Georgia (Hull Memorial and Eastern Heights) were affiliated with a hierarchical denomination, the Presbyterian Church in the United States.
- The congregations concluded the general church had departed from the faith and practice that existed when the congregations affiliated.
- Each congregation voted to withdraw and operate as an independent religious organization.
- A church tribunal associated with the general church asserted control over the local church properties.
- The local congregations sued in Georgia state court to enjoin the general church from entering and using the properties, without pursuing appeals within the church’s internal tribunal system.

## Issues

1. Whether the First Amendment permits civil courts to resolve church property disputes by determining whether a hierarchical church has departed from its doctrines under a “departure-from-doctrine” implied trust theory.
2. Whether a state may condition property rights on a civil court’s assessment of the meaning, importance, or continuity of religious doctrine.

## Decision

- The Supreme Court unanimously reversed the judgment of the Supreme Court of Georgia and remanded.
- The Court held that civil courts may not decide church property disputes by interpreting religious doctrine or deciding whether a church has “departed” from its tenets.
- The Court did not determine ownership of the disputed properties; it required further proceedings under constitutionally permissible methods that avoid ecclesiastical determinations.

## Legal Principles

- The First Amendment, applicable to the states through the Fourteenth Amendment, forbids civil adjudication of ecclesiastical questions.
- A property-dispute rule is unconstitutional if it requires a court or jury to assess whether a church has substantially abandoned or changed its doctrine.
- States may apply “neutral principles of law” to church property disputes (e.g., deeds, corporate charters, statutes, and relevant church governing instruments) only if the dispute can be resolved without deciding doctrinal questions.
- Civil enforcement of arrangements that condition property control on conformity with specific religious doctrine risks unconstitutional entanglement.

## Conclusion

The Court held that Georgia could not award church property based on a civil finding that the general church had departed from prior doctrine, because the First Amendment prohibits courts from interpreting and weighing religious doctrine to resolve property disputes.


Presbyterian Church in the United States v. Mary Elizabeth Blue Hull Memorial Presbyterian Church, 393 U.S. 440 (1969)