Jasvinder Singh, et al. v. Second Judicial District Court of Nevada, Washoe County, et al.

The church-autonomy doctrine shields religious institutions from civil-court interference in matters of internal governance, including church hierarchy and polity. This Court has recognized one caveat: Civil courts may still resolve disputes over the ownership of church property using secular, “neutral principles” of law, “developed for use in all property disputes.” See Presbyterian Church in U.S. v. Mary Elizabeth Blue Hull Mem’l Presbyterian Church, 393 U.S. 440, 449 (1969); Jones v. Wolf, 443 U.S. 595, 602–04 (1979). Though this Court has never extended the neutralprinciples approach beyond the property-ownership context, lower courts are split on whether to do so. Below, the Nevada Supreme Court expanded the doctrine beyond its property-law context, allowing a state court to adjudicate a dispute among members of the Northern Nevada Sikh Society over the Society’s membership and management. The question presented is: Whether the church-autonomy doctrine allows a civil court to invoke “neutral principles” beyond the property-ownership context, and thus to decide a religious institution’s internal governance dispute under organizational documents that define membership and authority in religious terms.