Maryland & Virginia Eldership of the Churches of God v. Church of God at Sharpsburg, Inc.

holding that a court’s resolution of a church property dispute did not involve an inquiry into religious doctrine when the court had assessed the language in deeds, the terms of corporate charters, and the terms of a church’s constitution | finding that a state court had jurisdiction to hear a church property dispute that did not “involve[] . . . inquir[ing] into religious doctrine | regional church sued local churches and others to prevent withdrawal from regional church and to determine control of church property | resolution of property dispute between church bodies was made on basis of state law, did not involve inquiry into religious doctrine, and therefore presented no substantial federal question | deference approach is permissible only where the governing church body can be determined without extensive inquiry into religious policy | deference approach is permissible only where the governing church body can be determined without extensive inquiry into religious policy | "[U]se of the Watson approach is consonant with the prohibitions of the First Amendment only if the appropriate church governing body can be determined without ... extensive inquiry into religious polity." | “[U]se of the Watson approach is consonant with the prohibitions of the First Amendment only if the appropriate church governing body can be determined without ... extensive inquiry into religious polity.” | "To permit civil courts to probe deeply enough into the allocation of power within a church so as to decide where religious law places control over the use of church property would violate the First Amendment in much the same manner as civil determination of religious doctrine." | “[W]here the identity of the governing body or bodies that exercise general authority within a church is a matter of substantial controversy, civil courts are not to make the inquiry into religious law and usage that would be essential to the resolution of the controversy.” | "To permit civil courts to probe deeply enough into the allocation of power within a church so as to decide where religious law places control over the use of church property would violate the First Amendment in much the same manner as civil determination of religious doctrine.”