Watson v. Jones
[3][2] Because the Walnut Street Presbyterian Church had a clear internal authority structure, the court granted control of the property to that group, even though it was only supported by a minority of the congregation.[2] Watson v. Jones was decided on common law grounds in a diversity action without explicit reliance on the First Amendment.A constitutionalization of the rule was made in Kedroff v. St. Nicholas Cathedral, in which the Court held unconstitutional a state statute that recognized the autonomy and authority of those North American branches of the Russian Orthodox Church which had declared their independence from the general church.Recognizing that Watson v. Jones had been decided on non-constitutional grounds, the Court thought nonetheless that the opinion "radiates .a spirit of freedom for religious organizations, and independence from secular control or manipulation—in short, power to decide for themselves, free from state interference, matters of church government as well as those of faith and doctrine."