In Presbyterian Church v. Hull Church (1969) 393 U.S. 440, signaled a significant shift in the high court's legal theory regarding church property disputes. There, the Supreme Court declared that: "The First Amendment severely circumscribes the role that civil courts may play in resolving church property disputes. ... Civil courts do not inhibit free exercise of religion merely by opening their doors to disputes involving church property. ... But First Amendment values are plainly jeopardized when church property litigation is made to turn on the resolution by civil courts of controversies over religious doctrine and practice. ... The First Amendment therefore commands civil courts to decide church property disputes without resolving underlying controversies over religious doctrine. Hence, States, religious organizations, and individuals must structure relationships involving church property so as not to require the civil courts to resolve ecclesiastical questions." (Ibid. at p. 449.) "Neutral principles of law, developed for use in all property disputes ... can be applied without 'establishing' churches to which property is awarded." (Id. at p. 449.)