The Protestant Episcopal Church in the Diocese of New Jersey, the Trustees of Church Property of the Diocese of New…

Summary

The Supreme Court of New Jersey affirmed the trial court's judgment that, because the Protestant Episcopal Church is a hierarchical organization, the Watson deference approach governs the dispute and the Diocese of New Jersey holds equitable title to St. Stephen's parish property. The Court also noted that a neutral‑principles analysis would reach the same result. Justice Schreiber dissented, arguing that the case should be decided by neutral principles of law and that deference to ecclesiastical authority would violate the Establishment Clause.