An Arizona court ruled that it was barred by the first amendment from resolving a dispute between a church and a priest concerning the termination of the priest's employment, but it could enforce a church's judgment authorizing an award of damages to the priest if it could do so without becoming "entangled" in church doctrine.
The Iowa Supreme Court suggested that it was barred by the first amendment guaranty of religious freedom from resolving a dispute involving the interpretation of church bylaws, but it refused to dismiss the case on procedural ground.
An Ohio court ruled that the members of a nonprofit corporation could not vote by proxy at a special business meeting since proxy voting was not authorized in the corporation's articles of incorporation or bylaws.
An Ohio court ruled that it could invalidate a church's election of a pastor if the election violated the church's bylaws and if it could resolve the dispute without any inquiry into religious doctrine.