This case presents two important questions
concerning the First Amendment's protection of
churches against the power of the state. A disaffected
faction of a Baptist church, without any authorization
from the church, sued the church leadership seeking
relief solely on behalf of the church . This faction sought
intrusive injunctive relief that would paralyze the
church and deliver it into the hands of the court, or the
plaintiffs.

This Court has long held that churches have a First
Amendment right "to decide for themselves, free from
state interference, matters of church government as well
as those of faith and doctrine." Kedroff v. St. Nicholas
Cathedral, 344 U.S. 94, 116 (1952). But the D.C. Court
of Appeals, along with two other lower courts, applies a
one-part "neutral principles of law" test to determine
whether the case raises any issues of "religious
doctrine." This inquiry focuses solely on the plaintiffs'
claims and not on the relief sought. Finding no
"doctrinal" issues, the Court of Appeals ruled for the
plaintiffs.

At least five lower courts, more faithful to Kedroff ,
add a second inquiry – whether the case intrudes
coercively into the internal affairs and governance of the
church.

And on the second question presented, there is a split
between the D.C. Court of Appeals and the D.C. Circuit.

The questions presented are:

I. Does the First Amendment require courts, in
applying "neutral principles of law" in a church dispute,
to consider (1) whether the judicial inquiry "intrudes
coercively into church governance" even when (2) there
is no "religious doctrinal" matter at issue?

II. Does the First Amendment require courts, in
applying "neutral principles of law" in a church dispute,
to analyze both (1) the claims and (2) the scope and
nature of the relief sought?

Does the First Amendment require courts to consider whether a judicial inquiry intrudes coercively into church governance even when there is no religious doctrinal matter at issue?