In 1871, the U.S. Supreme Court established the basic guidelines for when and how secular courts are to resolve disputes within religious organizations. Recognizing that some congregations are “strictly congregational or independent” and generally governed by a majority of their members, the court focused primarily on those which are “part of a large and general organization of some religious denomination” with which they are “more or less intimately connected by religious views and ecclesiastical government.” Watson v. Jones, 13 Wall (80 US) 679, 726 (1871).

Watson’s broad classification of churches as either congregational or hierarchical does not encompass the specific, nuanced realities of a local church’s multifaceted relationship with a denomination, such as the genesis and history of the relationship; the extent of ecclesiastical control exercised by the denomination over the local church; the doctrinal and governing documents of the denomination and the local church; as well as relevant governing statutes and legal precedent. Needless to say, “more or less” leaves lots of room for play.