The First Amendment prohibits courts from interfering in or determining religious disputes, out of concern that the government would become excessively entangled in essentially religious controversies or intervene on behalf of groups espousing particular doctrines or beliefs. This “ecclesiastical abstention” doctrine is meant to free religious bodies to decide disputes that are religious in nature by themselves, uninhibited by state interference.

New York courts often have to decide whether the ecclesiastical abstention doctrine applies in particular matters. The issue can be particularly complex when the dispute is between a local church and a higher church body in a hierarchical denomination to which the local church belongs. It is further complicated when significant property interests are involved. Indeed, whether the First Amendment precludes judicial review in a case involving religious institutions in a hierarchical system has confounded parties, counsel, and courts alike.