In Presbyterian Church v. Mary Elizabeth Blue Hull Mem. Presbyterian Church, 393 U.S. 440 (1969 Church, the Court examined "whether the restraints of the First Amendment . . . permit a civil court to award church property on the basis of the interpretation and significance the civil court assigns to aspects of church doctrine." Id. at 441. Although the Supreme Court stated, and the majority in the instant case noted, "there are neutral principles of law . . . which can be applied without 'establishing' churches to which property is awarded," Id. at 449, the Court also recognized that "special problems arise . . . when these disputes implicate controversies over church doctrine and practice." Id. at 445. Thus, when a Georgia court interpreted particular church doctrines and the importance of those doctrines to the religion, it "violated the command of the First Amendment." Id. at 449. The Court concluded that: "First Amendment values are plainly jeopardized when church property litigation is made to turn on the resolution by civil courts of controversies over religious doctrine and practice. If civil courts undertake to resolve such controversies in order to adjudicate the property dispute, the hazards are ever present of inhibiting the free development of religious doctrine and of implicating secular interests in matters of purely ecclesiastical concerns." Id. at 449.