2

Watson v. Jones, 80 U.S. 679 (1871). This significant consideration was based on three additional factors: (1) civil judges are incompetent to resolve questions of religious doctrine; (2) church members have voluntarily joined the church and have given their implied consent to its internal governance; and (3) the structure of our political system requires a severe limit on involvement by the civil courts in the affairs of religious bodies so as to secure religious liberty.