In Serbian Orthodox Diocese v. Milivojevich (1976) 426 U.S. 696, the United States Supreme Court held a civil court could not constitutionally invalidate an ecclesiastical decision to defrock a bishop. The decision to defrock the bishop had been made by an ecclesiastical tribunal of a hierarchical church. The Illinois Supreme Court had held the defrocking decision could be invalidated by a court because the church's action violated its own policies and rules. The United States Supreme Court concluded: "In short, under the guise of 'minimal' review under the umbrella of 'arbitrariness,' the Illinois Supreme Court has unconstitutionally undertaken the resolution of quintessentially religious controversies whose resolution the First Amendment commits exclusively to the highest ecclesiastical tribunals of this hierarchical church." (Id. at p. 720.)