In First Presbyt. Church of Schenectady v. United Presbyt. Church in U.S. of Am. (62 NY2d 110, 464 N.E.2d 454, 476 N.Y.S.2d 86 [1984]) the Court adopted the neutral principles of law approach to church property disputes set forth by the United States Supreme Court in Jones v. Wolf (443 US 595, 99 S Ct 3020, 61 L Ed 2d 775 [1979]). "Under the neutral-principles approach, the outcome of a church property dispute is not foreordained. At any time before the dispute erupts, the parties can ensure, if they so desire, that the faction loyal to the hierarchical church will retain the church property. They can modify the deeds or the corporate charter to include a right of reversion or trust in favor of the general church. Alternatively, the constitution of the general church can be made to recite an express trust in favor of the denominational church. The burden involved in taking such steps will be minimal. And the civil courts will be bound to give effect to the result indicated by the parties, provided it is embodied in some legally cognizable form" (Jones, 443 US at 606).