In Episcopal Church Cases (2009) 45 Cal.4th 467, the California Supreme Court described the following principles for adjudicating disputes within a religious organization: "The high court has approved two methods for adjudicating church property disputes. The first approach is one the court itself adopted in the 19th century. (Watson v. Jones (1871) 80 U.S. 679 20 L.Ed. 666.) This approach is often called the 'principle of government' approach. The Watson v. Jones court distinguished between two types of church disputes. One 'has reference to the case of a church of a strictly congregational or independent organization, governed solely within itself ... ; and to property held by such a church, either by way of purchase or donation, with no other specific trust attached to it in the hands of the church than that it is for the use of that congregation as a religious society.' 'In such cases,' the court explained, 'where there is a schism which leads to a separation into distinct and conflicting bodies, the rights of such bodies to the use of the property must be determined by the ordinary principles which govern voluntary associations.' Another type, which the court said 'is the one which is oftenest found in the courts,' involves a hierarchical structure, i.e., a 'religious congregation which is itself part of a large and general organization of some religious denomination, with which it is more or less intimately connected by religious views and ecclesiastical government.' In the latter case, the court said, 'we are bound to look at the fact that the local congregation is itself but a member of a much larger and more important religious organization, and is under its government and control, and is bound by its orders and judgments.' " (Episcopal Church Cases, supra, at p. 480.)