Internal Church Dispute Case Law

"Where an internal church dispute involves a question of ownership or control of church property which the civil courts can adjudicate by applying ' "neutral principles of law, developed for use in all property disputes," ' the civil courts may properly decide the issues in controversy. ( Jones v. Wolf (1979) 443 U.S. 595, 599-605 [61 L. Ed. 2d 775, 782-785, 99 S. Ct. 3020].) But where an internal church dispute turns on 'the resolution . . . of controversies over religious doctrine and practice,' not on a property question resolvable under 'neutral principles of law,' the civil courts may not adjudicate the dispute. (Presbyterian Church v. Hull Church (1969) 393 U.S. 440, 449 [21 L. Ed. 2d 658, 665, 89 S. Ct. 601]." ( Vukovich v. Radulovich (1991) 235 Cal. App. 3d 281, 291 [286 Cal. Rptr. 547].)