How have state and lower federal courts resolved church property disputes since Jones? A few courts have repudiated the neutral principles approach approved by the United States Supreme Court in Jones, and have adopted a rule of compulsory deference by the courts to the determinations of ecclesiastical commissions or judicatories in church property disputes, whether or not religious doctrine is implicated.[45] Townsend v. Teagle, 467 So.2d 772 (Fla. App. 1985); Fonken v. Community Church, 339 N.W.2d 810 (Iowa 1983) (rejecting the claim that "the compulsory deference approach is applicable only to purely ecclesiastical matters"); Calvary Presbyterian Church v. Presbytery of Lake Huron, 384 N.W.2d 92 (Mich. App. 1986); but cf. Bennison v. Sharp, 329 N.W.2d 466 (Mich. App. 1982); Tea v. Protestant Episcopal Church, 610 P.2d 181 (Nev. 1980); Protestant Episcopal Church v. Graves, 417 A.2d 19 ...
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