In Bruss v. Przybylo, 385 Ill. App. 3d 399, 895 N.E.2d 1102, 1122, 324 Ill. Dec. 387 (Ill. App. Ct. 2008) the Court explored both the Supreme Court's development of the ecclesiastical abstention doctrine from Watson v. Jones to Serbian Eastern Orthodox Diocese v. Milivojevich, and the current application of the doctrine by lower courts. Bruss, 895 N.E.2d at 1111-21. The Bruss court's analysis rests on the distinction between "subject-matter deference" and "procedural deference" in ecclesiastical matters. Id. at 1112. "Subject-matter deference" is the controlling principle of the ecclesiastical abstention doctrine. Id. It requires civil courts to abstain from determining ecclesiastical matters - including "a matter which concerns theological controversy, church discipline, ecclesiastical government, or the conformity of the members of the church to the standard of morals required of them." Id. at 1114.