By Jon Anderson
In Jones v. Wolf, 443 U.S. 595 (1979), the United States Supreme Court definitively established that states are “constitutionally entitled to adopt neutral principles of law as a means of adjudicating a church property dispute.” Since that time, courts have grappled with the scope of the neutral principles approach and whether this exception to church autonomy is limited to property dispute or whether or can also apply to tort and other types of disputes? Courts have reached differing results. The Nevada Supreme Court recently weighed in on this issue. Recognizing that “[s]tates are split as to whether the neutral-principles exception may apply beyond the context of church property disputes,” the court held: “[A]bsent Supreme Court authority holding otherwise, we now clarify that the neutral-principles exception to the ecclesiastical abstention doctrine may apply beyond real property disputes among church members. Rather, the relevant inquiry for courts to resolve is whether the court is able to apply neutral principles of law to resolve the issues at hand without consideration of ecclesiastical or doctrinal matters . . . Accordingly, the neutral-principles exception applies beyond the context of church property ownership disputes, so long as the court applying neutral principles can do so without resolving underlying controversies over religious doctrine.” Singh v. Second Jud. Dist. Ct. in & for Cnty. of Washoe, No. 90620, 2026 WL 903225, at *4-5 (Nev. Apr. 2, 2026) (internal quotations and citation omitted).
In Singh, members of the North Nevada Sikh Society, organized under Nevada’s nonprofits corporation law, filed suit against the Management Committee asserting breach-of-bylaws claims and for declaratory relief. The members alleged that the Management Committee had breached the bylaws by creating an interim committee and subcommittee without approval from the general members and authorizing the two committees to dispose of the entity’s assets, failing to issue membership cards to general members and maintain membership records, and (3) refusing to allow members to inspect the entity’s books and records. They also sought declaratory relief, asking the court to declare the actions of the Management Committee void, that the two committees lacked the authority to dispose of NNSS’s assets, and that the Management Defendants were not properly elected to the Management Committee by an election pursuant to NNSS’s bylaws. After holding that the neutral principles approach extends beyond property disputes, the court held that the NNSS members’ claims could be resolved utilizing neutral principles of law:
After reviewing the allegations in RPIs’ complaint and NNSS Management’s claims, we conclude that the ecclesiastical abstention doctrine does not apply, as the issues raised in the complaint do not require the district court to resolve ecclesiastical questions or consider Sikh doctrine, practice, or texts. RPIs alleged three breach-of-bylaws claims and a single claim for declaratory relief. RPIs assert these claims under NRS 82.216(1), maintaining that they arise from NNSS Management’s purported failure to follow NNSS’s bylaws in forming the two committees, attempting to place the Temple in trust, in not maintaining adequate membership records, and in restricting members from inspecting NNSS’s books and records. Contrary to NNSS Management’s assertions, RPIs’ claims do not require the district court to resolve whether the temple should be placed in a trust or any controversy over religious doctrine. Nor do they ask the district court to decide whether NNSS Management properly applied ecclesiastical rules when it engaged in the actions alleged by RPIs. Rather, RPIs ask the court to decide—under Nevada law and the secular governing corporate documents of NNSS—whether NNSS Management acted in accordance with NNSS’s bylaws.
Id. at *5.
Absent further guidance from the United States Supreme Court, the Singh decision illustrates the struggle and diverging opinions lowers courts will continue to have in determining the scope of the neutral principles approach.